Financial Audit: Process for Preparing the Consolidated Financial
Statements of the U.S. Government Continues to Need Improvement  
(04-MAY-05, GAO-05-407).					 
                                                                 
For the past 8 years, since the first audit of the consolidated  
financial statements of the U.S. government (CFS), certain	 
material weaknesses in internal control and in selected 	 
accounting and financial reporting practices have resulted in	 
conditions that prevented GAO from expressing an opinion on the  
CFS. Specifically, GAO has reported that the U.S. government did 
not have adequate systems, controls, and procedures to properly  
prepare the CFS. In December 2004, GAO reported on weaknesses	 
identified during its fiscal year 2004 audit of the CFS,	 
including weaknesses relating to the Department of the Treasury's
(Treasury) preparation of the CFS. The purpose of this report is 
to (1) discuss the details of the weaknesses relating to	 
Treasury's preparation of the CFS, (2) recommend improvements to 
address those weaknesses, and (3) provide the status of 	 
corrective actions to address the 142 open recommendations GAO	 
previously reported.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-407 					        
    ACCNO:   A23361						        
  TITLE:     Financial Audit: Process for Preparing the Consolidated  
Financial Statements of the U.S. Government Continues to Need	 
Improvement							 
     DATE:   05/04/2005 
  SUBJECT:   Accounting 					 
	     Accounting procedures				 
	     Financial records					 
	     Financial statement audits 			 
	     Internal controls					 
	     Reporting requirements				 
	     Financial statements				 
	     Audit reports					 
	     Accounting standards				 
	     Corrective action					 
	     Governmentwide Financial Reporting 		 
	     System						 
                                                                 

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GAO-05-407

United States Government Accountability Office

 GAO	Report to the Secretary of the Treasury and the Director of the Office of
                             Management and Budget

May 2005

FINANCIAL AUDIT

                                  Process for
                                 Preparing the
                                  Consolidated
                                   Financial
                               Statements of the
                                U.S. Government
                                  Continues to
                                Need Improvement

                                       a

GAO-05-407

[IMG]

May 2005

FINANCIAL AUDIT

Process for Preparing the Consolidated Financial Statements of the U.S.
Government Continues to Need Improvement

  What GAO Found

GAO identified weaknesses during its tests of Treasury's process for
preparing the fiscal year 2004 CFS. Such weaknesses in the CFS preparation
process impair the U.S. government's ability to ensure that the CFS is
consistent with the underlying audited agency financial statements,
properly balanced, and in conformity with U.S. generally accepted
accounting principles.

The weaknesses GAO identified during the fiscal year 2004 CFS audit
involved the following six areas:

o  directly linking audited federal agency financial statements to the
CFS,

o  controls over the compilation process,

o  consolidated reporting guidance to agencies,

o  	intragovernmental activity and balances-explanations for material
unreconciled transactions,

o  	consistency of the Department of Justice's and agencies' opinions on
legal cases, and

o  conformity with U.S. generally accepted accounting principles.

During fiscal year 2004, Treasury made progress in laying the foundation
to address certain long-standing material deficiencies in preparing the
CFS. Foremost is the ongoing development of a new system, which is
intended to directly link information from federal agencies' audited
financial statements to amounts reported in the CFS. Additional actions
are under way and planned.

Of the 142 open recommendations that GAO reported in September 2004
regarding the process for preparing the CFS, 135 remained open as of
December 6, 2004, the end of GAO's fieldwork for the fiscal year 2004 CFS
audit. However, 86 of these 135 recommendations relate to specific
disclosures required under U.S. generally accepted accounting principles.
Treasury has taken action to begin addressing the conformity with U.S.
generally accepted accounting principles issue. GAO plans to determine the
status of corrective actions to address its open recommendations during
its fiscal year 2005 audit of the CFS.

                 United States Government Accountability Office

Contents

  Letter

Results in Brief
Scope and Methodology
Directly Linking Audited Federal Agency Financial Statements to

the CFS Controls over the Compilation Process Consolidated Reporting
Guidance to Agencies Intragovernmental Activity and Balances-Explanations
for

Material Unreconciled Differences Consistency of Justice's and Agencies'
Opinions on Legal Cases Conformity with U.S. Generally Accepted Accounting
Principles Agency Comments and Our Evaluation

1 2 5

                                                                       6 7 12

14 15 16 17

Appendixes

Appendix I: Disclosure Issues 23

Appendix II:	Status of Treasury's and OMB's Progress in Addressing GAO's
Prior Year Recommendations for Preparing the CFS 25

Appendix III: Comments from the Department of the Treasury 73

Abbreviations

CFS consolidated financial statements of the U.S. government
FASAB Federal Accounting Standards Advisory Board
GAAP generally accepted accounting principles
GFRS Governmentwide Financial Reporting System
Justice Department of Justice
OMB Office of Management and Budget
PBGC Pension Benefit Guaranty Corporation
SFFAS Statement of Federal Financial Accounting Standards
TFM Treasury Financial Manual
Treasury Department of the Treasury
VA Department of Veterans Affairs

Contents

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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copyright holder may be necessary if you wish to reproduce this material
separately.

A

United States Government Accountability Office Washington, D.C. 20548

May 4, 2005

The Honorable John W. Snow The Secretary of the Treasury

The Honorable Joshua B. Bolten Director, Office of Management and Budget

In our report dated December 6, 2004, we disclaimed an opinion on the
consolidated financial statements of the U.S. government (CFS) for the
fiscal years ended September 30, 2004 and 2003.1 For the past 8 years,
certain material weaknesses in internal control and in selected accounting
and financial reporting practices resulted in conditions that prevented us
from expressing an opinion on the CFS. Specifically, we have reported that
the federal government did not have adequate systems, controls, and
procedures to properly prepare its consolidated financial statements. Many
of these weaknesses in internal control that contributed to our continuing
disclaimers of opinion were identified by agency financial statement
auditors during their audits of federal agencies' financial statements and
were reported in detail with recommendations to the agencies in separate
reports. However, some of the internal control weaknesses were identified
during our tests of the Department of the Treasury's (Treasury) process
for preparing the CFS.

Such weaknesses in the CFS preparation process impair the federal
government's ability to ensure that the CFS is consistent with the
underlying audited agency financial statements, properly balanced, and in
conformity with U.S. generally accepted accounting principles (GAAP).
Consequently, these weaknesses also contributed to our inability to render
an opinion on the CFS.

The purpose of this report is to (1) discuss the details of the weaknesses
we identified during our fiscal year 2004 audit regarding financial
reporting procedures and internal control over the process for preparing
the CFS, (2) recommend improvements to address those weaknesses, and (3)
provide the status of corrective actions to address the

1 The fiscal year 2004 Financial Report of the United States Government
includes
our report and was completed by the Department of the Treasury (Treasury)
on
December 15, 2004, and is available through GAO's Web site at
www.gao.gov/financial.html
and Treasury's Web site at www.fms.treas.gov/fr/index.html.

open recommendations detailed in our prior reports and listed in appendix

II. We have discussed each of the new weaknesses identified during our
fiscal year 2004 audit with your staff and have incorporated their
comments as appropriate.

Results in Brief	We identified weaknesses in the compilation and reporting
processes during our fiscal year 2004 audit. Specifically, we found that

o 	Treasury's process for compiling the CFS does not yet ensure that
financial information from federal agencies' audited financial statements
and other financial data directly link to amounts reported in the CFS;

o 	Treasury's process for compiling the CFS has weaknesses in internal
control, including a lack of adequate segregation of duties and management
reviews of certain key data;

o 	Treasury did not provide clear guidance to federal agencies about
certain financial information that they were required to provide Treasury
to be compiled in the CFS and Treasury and the Office of Management and
Budget (OMB) did not perform follow-up procedures to ensure we had all the
necessary audit documentation to perform certain of our audit procedures
relating to the compilation of the CFS;

o 	Treasury does not require federal agencies to provide detailed
explanations for all material differences identified in the
intragovernmental reconciliations that Treasury and OMB require the
agencies to perform;

o 	Treasury does not have specific policies and procedures to address
discrepancies of opinion between the Department of Justice's (Justice) and
applicable federal agencies' legal counsel for purposes of providing legal
representations to us at the governmentwide level; and

o 	Treasury continues to lack an adequate process to ensure that the
financial statements, related notes, stewardship information, and
supplementary information in the CFS are presented in conformity with
GAAP.

During fiscal year 2004, Treasury made progress in laying the foundation
to address certain long-standing material deficiencies in preparing the
CFS.

Foremost is the ongoing development of a new system, which is intended to
directly link information from federal agencies' audited financial
statements to amounts reported in the CFS. Additional actions are under
way and planned.

This report includes 20 new recommendations to address the weaknesses we
identified during our fiscal year 2004 CFS audit, including 6 related to
three required GAAP disclosure areas identified in appendix I. Consistent
with our position on previously identified disclosure weaknesses, we are
recommending that the required disclosures that are not included in the
fiscal year 2004 CFS either be included in future years' CFS or that the
specific basis for their exclusion be documented. Appendix II of this
report reflects the status of actions taken as of December 6, 2004, the
date of completion of our fieldwork on our fiscal year 2004 CFS audit, to
address the open recommendations from our previous reports and shows that
135 recommendations contained in our prior reports remain open and 7 were
closed during our fiscal year 2004 audit. However, 86 of these 135
recommendations relate to specific disclosures required under GAAP.
Treasury has taken action to begin addressing the conformity with GAAP
issue. We plan to determine the status of corrective actions to address
our open recommendations during our fiscal year 2005 audit of the CFS.

OMB stated that it generally agreed with the new findings and related
recommendations in this report. Treasury stated that it agrees that the
reporting process still needs improvement and that it is addressing many
of the recommendations in our previous reports. Treasury also stated that
it generally concurs with our new recommendations and that it will work
with OMB and the federal agencies to improve reporting practices. Also,
Treasury asked that we reconsider or modify our recommendations in three
areas: (1) controls over the compilation process, (2) consistency of
Justice's and agencies' opinions on legal cases, and (3) directly linking
audited federal agency financial statements to the CFS. We modified
recommendations in the first two areas.

With regard to controls over the compilation process, we found that
Treasury did not have adequate supporting documentation for several
journal vouchers to adjust data submitted by agencies in their audited
closing packages. Treasury stated that it agrees that there are instances
where it should obtain agency approvals before changing federal agencies'
audited data when compiling the CFS, but it needs the flexibility and
authority to make appropriate adjustments when needed regardless of
whether agencies agree and asked that we modify our recommendation

accordingly. Treasury believes that agency approval is not necessary when
certain adjustments to agencies' closing package data are made. Treasury
is correct that certain circumstances may require adjustments to agency
closing package data. In such instances, we believe that Treasury should
contact agencies to resolve any discrepancies between agencies' audited
closing packages and audited financial statements and discuss any other
situations that require adjustments to agencies' audited closing package
data. The purpose of our recommendation was to provide improved controls
over adjustments made to agencies' data and was not intended to limit
Treasury's flexibility in preparing the CFS. We have modified our
recommendation to clarify our intent.

With regard to consistency of Justice's and agencies' opinions on legal
cases, Treasury stated that it and OMB have agreed that Justice is the
final authority on legal liabilities and disclosure amounts at the
governmentwide level. Treasury also stated that it will work with OMB to
develop a policy to eliminate any inconsistencies between Justice's and
federal agencies' opinions on legal cases. We have modified our
recommendation to reflect that Treasury and OMB will work jointly to
address the issue.

With regard to directly linking audited federal agency financial
statements to the CFS, Treasury continues to disagree that additional
information should be collected from federal agencies' audited financial
statements to demonstrate consistency and completeness of reporting for
both the Reconciliation of Net Operating Cost and Unified Budget Deficit
and the Statement of Changes in Cash Balance from Unified Budget and Other
Activities. For fiscal year 2004, these two financial statements included
some amounts that Treasury could not explain or fully support or for which
Treasury could not demonstrate the link to agencies' audited financial
statements. We continue to believe that the process of directly linking
relevant audited federal agencies' financial statement information to
these two financial statements would be the most efficient and effective
manner for Treasury, as the preparer of the CFS, to obtain and demonstrate
the necessary assurance on certain information reported in such financial
statements. As such, we have not modified our recommendations in this
area.

As part of our audit of the fiscal years 2004 and 2003 CFS, we evaluated
Treasury's financial reporting procedures and related internal control and
we followed up on the status of Treasury and OMB corrective actions to
address open recommendations regarding the process for preparing the CFS
that were in our prior years' reports. In our report, which is included in
the fiscal year 2004 Financial Report of the United States Government, we
reported material deficiencies relating to Treasury's preparation of the
CFS. These material deficiencies contributed to our disclaimer of opinion
on the CFS and also constitute material weaknesses in internal control,
which contributed to our adverse opinion on internal control. We performed
sufficient audit procedures to provide the disclaimer of opinion in
accordance with U.S. generally accepted government auditing standards.
This report provides the details of the additional weaknesses we
identified in performing our fiscal year 2004 audit procedures and our
recommendations to correct those weaknesses, as well as the status of
corrective actions taken by Treasury and OMB to address open
recommendations contained in our prior years' reports.

We requested comments on a draft of this report from the Director of OMB
and the Secretary of the Treasury or their designees. OMB provided oral
comments, which are discussed in the Agency Comments and Our Evaluation
section of this report. Treasury's comments are reprinted in appendix III
and are also discussed in the Agency Comments and Our Evaluation section.

  Directly Linking Audited Federal Agency Financial Statements to the CFS

As we have reported in the past, Treasury's process for compiling the CFS
does not yet ensure that financial information from federal agencies'
audited financial statements and other financial data directly link to
amounts reported in the CFS. Statement of Federal Financial Accounting
Concepts No. 4, Intended Audience and Qualitative Characteristics for the
Consolidated Financial Report of the United States Government, states that
the consolidated financial report should be a general purpose report that
is aggregated from agency reports and that it should tell users where to
find information in other formats, both aggregated and disaggregated, such
as in individual agency reports, on agency Web sites, and in the
President's Budget. In our prior report,2 we recommended that as Treasury
continues to design and further implement its new process for compiling
the CFS, the Secretary of the Treasury direct the Fiscal Assistant
Secretary, in coordination with the Controller of the OMB, to modify
Treasury's closing package to (1) require federal agencies to directly
link their audited financial statement notes to the CFS notes and (2)
provide the necessary information to demonstrate that all of the five
principal consolidated financial statements are consistent with the
underlying information in federal agencies' audited financial statements
and other financial data.

As discussed in our fiscal year 2004 audit report, Treasury made progress
in laying the foundation to address certain long-standing material
deficiencies in preparing the CFS. Foremost is the ongoing development of
a new system, the Governmentwide Financial Reporting System (GFRS), to
collect agency financial statement information taken directly from federal
agencies' audited financial statements rather than using federal agencies'
Standard General Ledger data, as Treasury had done in previous years to
compile the CFS. The goal of the new system is to be able to directly link
information from federal agencies' audited financial statements to amounts
reported in the CFS, a concept that we strongly support. Once Treasury is
able to achieve this, a major impediment to our ability to audit the CFS
would be eliminated.

2 GAO, Financial Audit: Process for Preparing the Consolidated Financial
Statements of the U.S. Government Needs Further Improvement, GAO-04-866
(Washington, D.C.: Sept. 10, 2004).

Based on our review of Treasury's new process for compiling the CFS, we
found that Treasury was unable to demonstrate that the information in the
fiscal year 2004 CFS directly linked to agencies' audited financial
statements. Even though Treasury required each significant agency3 to
submit its audited financial statement data in the GFRS closing package
and certify their accuracy, the closing package does not require federal
agencies to directly link their audited financial statement notes to the
closing package notes and does not require the necessary information to
compile all five of the required consolidated financial statements. In
some cases, we found that Treasury was unable to demonstrate that the
financial information in the CFS directly linked to federal agencies'
audited financial statements because federal agencies provided Treasury
with incomplete and inaccurate financial information. Also, because of
other internal control weaknesses over the compilation process noted in
this report, Treasury could not fully ensure that the information in the
CFS was consistent with underlying information in agencies' audited
financial statements and other financial data.

  Controls over the Compilation Process

We continued to find that there are specific areas of internal control in
Treasury's process for compiling the CFS that need to be strengthened.
Treasury had to resort to last-minute, alternative methods to gather the
needed fiscal year 2004 information. These problems were compounded by
Treasury's reliance on internal controls that were dependent on procedures
that would attempt to identify any errors after they were made by an
agency (detective controls) rather than on internal controls that may have
prevented or minimized the errors from occurring (preventive controls).
Treasury had planned to perform certain tests of its new fiscal year 2004
process and design the necessary internal controls by collecting agencies'
fiscal year 2003 financial information during the summer of fiscal year
2004. Although Treasury did collect the fiscal year 2003 financial
information, it did not perform the necessary detailed tests to identify
and correct potential issues with its new reporting process and develop
adequate internal control for the fiscal year 2004 reporting process.

3 Treasury refers to the significant agencies as "verifying agencies."
They are the Chief Financial Officers Act agencies, the Export-Import Bank
of the United States, the Farm Credit System Insurance Corporation, the
Federal Communications Commission, the Federal Deposit Insurance
Corporation, the National Credit Union Administration, the U.S. Postal
Service, the Pension Benefit Guaranty Corporation, the Railroad Retirement
Board, the Securities and Exchange Commission, the Smithsonian
Institution, and the Tennessee Valley Authority.

Internal control should provide, among other things, reasonable assurance
that financial reporting is reliable. GAO's Standards for Internal Control
in the Federal Government4 defines the minimum level of quality acceptable
for internal control in the federal government and provides the standards
against which internal control is to be evaluated. These standards state
that internal controls should include (1) segregation of duties, (2)
appropriate documentation of transactions and internal control, (3)
reviews by management at the functional or activity level, and (4) access
controls over information systems. We found many internal controls in
place, but we also continued to identify areas that need to be improved,
as well as the need for a strong financial reporting infrastructure. As
Treasury continues to develop its new compilation process, implementing
adequate internal control remains important and needs to be considered
during the development process.

Segregation of Duties	Segregation of duties is the practice of dividing
the steps in a critical function among different individuals in order to
reduce the risk of error, thus preventing a single individual from having
full control of a transaction or event. Lack of proper segregation of
duties for critical processes leaves the CFS vulnerable to errors and
could result in incomplete and inaccurate summarization of data within
these financial statements. During our fiscal year 2004 audit, we
identified a lack of segregation of duties over (1) Treasury's new process
for preparing governmentwide adjustments to the financial statements,(2)
the process for making changes to Excel spreadsheets that contain audited
agency financial information, and (3) access to federal agencies' closing
package data in Treasury's new system. The lack of segregation of duties
over these areas allowed a single Treasury employee to perform functions
that should have been divided among several employees. In each of the
following examples, a single Treasury employee was allowed to

o 	determine and approve the amount of a journal voucher to adjust the
financial statements,

o 	solely determine needed changes to the Excel spreadsheets and make the
changes without obtaining any approval, and

4 GAO, Internal Control: Standards for Internal Control in the Federal
Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

o 	have access to agency closing package data entered in Treasury's new
system by individual agencies and edit the same information without
obtaining approval from the agency.

    Appropriate Documentation of Transactions and Internal Control

Agency management is responsible for developing appropriate detailed
policies, procedures, and practices to perform agency operations and
ensuring that internal control is an integral part of operations. Although
GAO's Standards for Internal Control in the Federal Government calls for
clear documentation of policies and procedures and transactions, we
continued to find that many key policies and procedures were not
documented in Treasury's standard operating procedures and that Treasury
did not have appropriate supporting documentation for all transactions
recorded in the CFS.

In our prior report,5 we recommended that the Secretary of the Treasury
direct the Fiscal Assistant Secretary to develop and fully document
policies and procedures for the consolidated financial statement
preparation process so that they are proper, complete, and consistently
applied among staff members. Without documented policies and procedures,
staff could apply practices inconsistently or not perform necessary
practices at all. However, during our fiscal year 2004 audit, we found
that Treasury had not fully documented its policies and procedures for
preparing the CFS before the fiscal year 2004 process began and continued
to develop its policies and procedures throughout our audit and up to the
end-of-fieldwork date. Treasury's standard operating procedures did not
include the following key procedures:

o 	procedures for correcting any errors identified in agencies' closing
packages;

o 	detailed and comprehensive procedures for the allocation of certain
costs on the statement of net cost; and

o 	procedures for compiling information that was not collected in GFRS or
Excel spreadsheets, such as how to properly analyze and compile
contingency information.

5 GAO, Financial Audit: Process for Preparing the Consolidated Financial
Statements of the U.S. Government Needs Improvement, GAO-04-45
(Washington, D.C.: Oct. 30, 2003).

Also, Treasury did not have appropriate supporting documentation for all
transactions recorded in the CFS. Recording transactions in the financial
statements without adequate underlying support increases the risk that
inappropriate adjustments to balances in the financial statements could be
made. Specifically, we found that 20 of the 51 journal vouchers recorded
in Treasury's journal voucher log did not have adequate supporting
documentation. Eighteen of these journal vouchers were necessary because
agencies submitted data in their closing packages that did not agree to
their audited financial statements. Treasury did not document
communications with these agencies before recording such adjustments. For
example, we found that the supporting documentation for 13 fiscal year
2004 journal vouchers to correct agency data was simply a printout from
GFRS or a copy of a page from an agency's financial statements without any
agency confirmation of the correction. We also found that some significant
changes were made directly to the CFS and not through the journal voucher
process or any other formal documentation process.

Management Review	During our fiscal year 2004 audit, we found that
Treasury management did not review transactions within several key
compilation processes. Transactions and other significant events should be
authorized and executed only by persons acting within the scope of their
authority. Appropriate reviews by management of key decisions and data are
vital controls to ensure that only authorized actions occur. Inadequate
management reviews and lack of documentation of changes, reviews, and
approvals could allow the CFS to be manipulated or changed without any
supervisory control or review, resulting in the possibility that agency
data could be changed or incorrectly compiled in the CFS. For example, we
found that some changes to the Excel spreadsheets used to compile agency
financial information were not documented, and therefore, there was no
documentation of review and approval from management. We also found that
not all journal vouchers were approved by management before being recorded
in the CFS. In some cases, the lack of management review was the result of
improperly segregating duties as discussed above.

Access Controls over During our fiscal year 2004 audit, we found that
information system control

Information Systems	weaknesses, including inadequate access controls,
existed within the segments of GFRS used during the fiscal year 2004
reporting process. Access controls should provide reasonable assurance
that computer resources are protected against unauthorized modification,
disclosure, loss, or impairment. Limiting access ensures that access to
very sensitive

resources is limited to very few individuals and that employees are
restricted from performing incompatible functions or functions beyond
their responsibility. Treasury's lack of adequate controls to prevent
inappropriate access increases the risk of unauthorized information or
computer resource modification, disclosure, loss, or impairment.
Specifically, we found that inappropriate access to GFRS was granted to
certain Treasury personnel, and the GFRS database was not configured to
prevent the unauthorized alteration of data submitted by federal agencies.
We also found that the GFRS production database was also used for testing,
which could result in inadvertent alteration of the production data used
to compile the CFS.

    Financial Reporting Infrastructure

During our fiscal year 2004 audit, Treasury did not have the
infrastructure to address the magnitude of the fiscal year 2004 financial
reporting challenges it faced, such as an incomplete financial reporting
system, compressed time frames for compiling the financial information,
and inaccurate and incomplete information provided by certain federal
agencies. As a result, we found that Treasury's Financial Management
Service personnel had excessive workloads and that an extraordinary amount
of effort and dedication was required to compile the CFS. Also, too few
Financial Management Service personnel had the specialized financial
reporting experience necessary to ensure accurate and reliable financial
reporting by the accelerated reporting date. We found that there was a
heavy reliance on just a few personnel to perform key functions without
any trained backup employees. If these personnel were unavailable,
Treasury's financial reporting process would be negatively affected.

    Recommendations for Executive Action

In connection with Treasury's development of its new compilation system
and process, we recommend that the Secretary of the Treasury direct the
Fiscal Assistant Secretary to

o 	segregate the duties of individuals performing key functions in
Treasury's processes for preparing governmentwide adjustments to the
financial statements, making changes to Excel spreadsheets that contain
audited agency financial information, and accessing federal agencies'
closing package data in Treasury's new system;

o 	require and maintain appropriate supporting documentation for all
journal vouchers recorded in the CFS;

o 	require that Treasury employees contact and document communications
with agencies before recording journal vouchers to change agency audited
closing package data;

o 	require and document management reviews of all procedures that result
in data changes to the CFS;

o 	configure the GFRS database to prevent Treasury personnel from altering
data submitted by federal agencies and to use separate GFRS databases for
testing and production; and

o 	assess the infrastructure associated with the compilation process and
modify it as necessary to achieve a sound internal control environment.

  Consolidated Reporting Guidance to Agencies

The Treasury Financial Manual (TFM) prescribes how federal agencies are to
submit financial information to Treasury to be compiled in the CFS. While
our planned audit procedures were not to review the entire TFM to
determine if its guidance to agencies was clear, we found several areas
where the TFM did not give clear guidance to federal agencies about the
information that they were required to provide in the notes to the
financial statements. Specifically, we found that the TFM did not give
clear guidance for reporting note disclosures for loans receivable and
loan guarantees; property, plant, and equipment; federal employee and
veteran benefits payable; and contingencies. Also, the TFM did not provide
clear guidance on how to consistently report debit and credit amounts
throughout various notes so that like amounts are appropriately added and
subtracted. For example, we noted that the TFM did not provide
instructions about which line in the property, plant, and equipment note
should include land improvements. As a result, agencies reported financial
data inconsistently. This increases the risk of incomplete and inaccurate
summarization of data in the CFS.

The TFM required federal agencies to also provide GAO, as the principal
auditor of the CFS, a complete closing package consisting of the special
purpose audit opinion, the management representation letter for the
closing package, audit trail report (reclassification journal voucher
report), closing package financial statement report, trading partner
summary report, notes reports, and other data reports. Certain federal
agencies did not provide us with complete closing packages. For example,
many federal agencies did not provide the audit trail report, which is a
vital report demonstrating the linkage between agencies' audited financial
statement

line items and the CFS line items. Treasury and OMB did not perform
follow-up procedures to obtain missing information from those agencies to
ensure that we had all the necessary audit documentation to perform our
audit procedures.

    Recommendations for Executive Action

We recommend that the Secretary of the Treasury direct the Fiscal
Assistant Secretary to review the TFM and any other guidance to federal
agencies to ensure that they provide clear instructions for reporting
accurate data to Treasury in the following specific areas:

o  loans receivable and loan guarantees;

o  property, plant, and equipment;

o  federal employee and veteran benefits payable;

o  contingencies; and

o  reporting debit and credit amounts.

We also recommend that the Director of OMB direct the Controller of the
Office of Federal Financial Management, in coordination with the Fiscal
Assistant Secretary, to ensure that federal agencies submit to GAO a
complete closing package, as required by the TFM as part of the
consolidation process, consisting of the

o  special purpose audit opinion,

o  management representation letter for the closing package,

o  audit trail report (reclassification journal voucher report),

o  closing package financial statement reports,

o  trading partner summary reports,

o  notes reports, and  o  other data reports.

  Intragovernmental Activity and Balances- Explanations for Material
  Unreconciled Differences

OMB and Treasury require federal agencies to reconcile selected
intragovernmental activity and balances with their "trading partners"6 and
report on the extent and results of the reconciliation efforts to
Treasury. As part of the reconciliation report, federal agencies were
required to categorize any material differences, as determined by
Treasury, with their trading partners at fiscal year-end within five
categories: (1) confirmed reporting (in which the agency is stating that
it has confirmed its balance to be correct); (2) accounting methodology
differences; (3) accounting or reporting errors; (4) timing
difference-current year, timing difference- prior year; and (5)
unknown/unreconciled. If a federal agency selects the category "accounting
methodology differences," it is also required to provide a detailed
explanation. However, Treasury does not require federal agencies to
provide any detailed explanations for the material differences reported in
any other category selected. Lack of detailed explanations may hinder
efforts to identify and correct problems that federal agencies are
experiencing in reconciling with their trading partners.

Recommendation for As Treasury continues to make strides to address issues
related to

Executive Action	intragovernmental transactions, we recommend that the
Secretary of the Treasury direct the Fiscal Assistant Secretary, working
in coordination with the Controller of OMB, to require that federal
agencies provide detailed explanations for all material differences
identified in the intragovernmental reconciliations.

6 Trading partners are U.S. government agencies, departments, or other
components included in the CFS that do business with each other.

  Consistency of Justice's and Agencies' Opinions on Legal Cases

For each agency financial statement audit, generally accepted government
auditing standards require that the agency auditors obtain written legal
representations as part of the audit. Legal representation letters, along
with related management schedules,7 are essential to properly reporting
the possible effects of litigation on federal agency financial statements.
Legal counsel's assessment of the likelihood of an unfavorable outcome and
the estimated potential losses on its agency's cases are the basis for
reporting legal contingencies in the financial statements and making
related disclosures in the notes. Inconsistent assessments on the
likelihood of an unfavorable outcome or estimated potential losses for the
same cases by Justice and agency legal counsel limit both the ability of
management to determine the proper accounting treatment in the CFS in
accordance with GAAP and GAO's ability to audit the CFS.

Generally, Justice is charged with the supervision of litigation to which
the U.S. government or its departments, agencies, officers, or employees
are a party and with providing advice and opinions to the President and
the heads of the executive departments of the U.S. government, when
requested. Accordingly, Justice has a special role in ensuring that we
receive legal representations to conduct our audit of the CFS in
accordance with generally accepted government auditing standards. During
our audit, we noted that the opinion of Justice's legal counsel on certain
agencies' legal cases differed from the opinion of the respective
individual federal agencies' legal counsel on such cases. For example, one
agency estimated its probable losses for certain cases, yet Justice's
legal counsel reported that it was not able to estimate the potential
losses for the same cases. In another legal case involving multiple
agencies, legal counsel from each of the agencies had a differing
assessment of the legal case's outcome, while Justice's legal counsel was
unable to provide an assessment. Treasury did not have specific policies
and procedures to address discrepancies of opinion between Justice's and
applicable agencies' legal counsel.

7 Office of Management and Budget, Audit Requirements for Federal
Financial Statements, OMB-01-02 (Washington, D.C.: Oct. 16, 2000),
requires each agency chief financial officer to prepare a management
schedule that documents how the information obtained in the legal
counsel's response was considered in preparing the financial statements.

Recommendation for We recommend that the Secretary of the Treasury direct
the Fiscal

Executive Action	Assistant Secretary, working in coordination with the
Controller of OMB's Office of Federal Financial Management, to develop
policies and procedures to determine the proper resolution and the
appropriate legal representations to GAO at the governmentwide level when
Justice's legal counsel and agencies' legal counsel provide inconsistent
opinions.

  Conformity with
  U.S. Generally
  Accepted Accounting
  Principles

As we have reported in previous years, and noted again during our fiscal
year 2004 audit, Treasury lacks an adequate process to ensure that the
financial statements, related notes, stewardship information, and
supplemental information in the CFS are presented in conformity with
GAAP. Statement of Federal Financial Accounting Standards No. 24,

Selected Standards for the Consolidated Financial Report of the United
States Government, states that the Federal Accounting Standards Advisory
Board (FASAB) standards apply to all federal agencies, including the
U.S. government as a whole, unless provision is made for different
accounting treatment in a current or subsequent standard. In our prior
report,8 we recommended that the Secretary of the Treasury direct the
Fiscal Assistant Secretary to establish a formal process that will cause
the
financial statements, related notes, stewardship information, and
supplemental information in the CFS to be presented in conformity with
GAAP in all material respects. The process should

o  timely identify GAAP requirements;

o 	make timely modifications to Treasury's closing package requirements to
obtain information needed;

o 	assess, qualitatively and quantitatively, the impact of any omitted
disclosures;9 and

o  document decisions reached and the rationale for such decisions.

8 GAO-04-45.

9 An item's omission or error is considered material if the surrounding
circumstances make it probable that the judgment of a reasonable person
relying on the information would have been changed or influenced by the
inclusion or correction of the item.

However, during fiscal year 2004, Treasury did not implement our
recommendations. As a result of our prior audits, recommendations related
to 86 specific disclosures that may not have been in conformity with
applicable standards remain open. During our fiscal year 2004 audit, we
identified 6 additional specific disclosures required by applicable
standards that were not included in the CFS. These additional required
disclosures are described in appendix I. Treasury did not provide us with
documentation of its rationale for excluding this information. As a result
of this and certain of the material deficiencies identified during the
fiscal year 2004 audit, we were unable to determine if the missing
information was material to the CFS. Treasury has not yet begun an annual
process to determine the proper GAAP disclosures. However, in an effort to
begin addressing this issue, Treasury collected certain additional note
information required by GAAP in its new process for fiscal year 2004.
However, due to the compressed time frames to compile the CFS and because
GFRS is still being developed, Treasury did not analyze such information
in preparing the fiscal year 2004 CFS. Treasury plans to analyze this
information in fiscal year 2005 and determine how or whether to disclose
this information in future years' CFS.

Recommendations for With respect to the six specific disclosures related
to three disclosure areas

Executive Action	identified in appendix I for which information was either
not included in the CFS or was presented in a way that did not meet GAAP
standards, we recommend that the Secretary of the Treasury direct the
Fiscal Assistant Secretary to include each of the six specific disclosures
in the CFS or document the specific rationale for excluding any of them.

  Agency Comments and Our Evaluation

OMB Comments	In oral comments on a draft of this report, OMB stated that
it generally agreed with the new findings and related recommendations in
this report. In addition, OMB provided some technical comments, which we
have incorporated as appropriate.

Treasury Comments	In written comments on a draft of this report, which are
reprinted in appendix III, Treasury stated that it agrees that the
reporting process still needs improvement and that it is addressing many
of the recommendations in our previous reports. Treasury also stated that
it generally concurs with our new recommendations and that it will work
with OMB and the federal agencies to improve reporting practices. Also,
Treasury asked that we reconsider or modify our recommendations in three
areas: (1) controls over the compilation process, (2) consistency of
Justice's and agencies' opinions on legal cases, and (3) directly linking
audited federal agency financial statements to the CFS. We modified
recommendations in the first two areas.

Controls over the Compilation Treasury stated that it agrees that there
are instances where it should

Process	obtain agency approvals before changing federal agencies' audited
data when compiling the CFS. However, Treasury also stated that it, as the
preparer of the CFS, needs the flexibility and authority to make
appropriate adjustments when needed regardless of whether federal agencies
agree and asked that we modify our recommendation accordingly. Treasury
believes that agency approval is not necessary when adjustments are
required to (1) make agency closing packages agree with their financial
statements, (2) apply a consistent application of an accounting principle
between agencies, and (3) make an agency conform to GAAP. In this regard,
the premise of the new compilation process is that the federal agencies'
audited closing package provides a direct link from agencies audited
financial statements to the CFS. Without that link, a timely and effective
audit is not possible. Federal agencies receive audit opinions on their
closing packages, and therefore, any adjustments that are necessary to
agencies' audited closing package data should be discussed with the
agencies. Treasury is correct that certain circumstances may require
adjustments to agency closing package data. In such instances, Treasury
should contact agencies to resolve any discrepancies between agencies'
audited closing packages and audited financial statements and to discuss
any other situations that require adjustments to agencies' audited closing
package data.

These communications should be documented and maintained as supporting
documentation for any resulting journal vouchers. This could be done by
e-mail. During our fiscal year 2004 audit of the CFS, we found that
Treasury did not have adequate supporting documentation for several
journal vouchers to adjust data submitted by agencies in their audited
closing packages. Treasury's supporting documentation for some of these

Consistency of Justice's and Agencies' Opinions on Legal Cases

Directly Linking Audited Federal Agency Financial Statements to the CFS

journal vouchers was simply a printout from GFRS or a copy of a page from
an agency's financial statements. The purpose of our recommendation is to
provide improved controls over adjustments made to federal agencies'
closing package data and was not intended to limit Treasury's flexibility
in preparing the CFS. We have modified our recommendation to clarify our
intent that Treasury should contact and document communications with
agencies before recording journal vouchers to change agencies' audited
closing package data.

Treasury stated that with regard to the governmentwide legal letter,
Treasury and OMB have agreed that Justice is the final authority on legal
liabilities and disclosure amounts. Treasury also stated that it will work
with OMB to develop a policy to eliminate any inconsistencies between
Justice's and the agencies' opinions on legal cases. We have modified our
recommendation to reflect that Treasury and OMB will work jointly to
address the issue.

Treasury stated that it recognizes the value and need for the CFS to be
consistent with the underlying agency financial statements, and it looks
to improve its process for compiling the CFS to allow for the expanded
traceability of the federal agencies' audited financial statement note
data to the CFS notes. However, Treasury continues to disagree that
additional information should be collected through the closing package
from federal agencies' audited financial statements to demonstrate
consistency and completeness of reporting for both the Reconciliation of
Net Operating Cost and Unified Budget Deficit and the Statement of Changes
in Cash Balance from Unified Budget and Other Activities-two of the five
principal financial statements.10

Treasury acknowledged that problems with these two statements need to be
resolved, but does not believe that rolling up federal agencies' reported
data will help to improve these statements. Treasury stated that the FASAB
standard related to the two statements makes clear that agency-reported
data are not relevant to these statements. We disagree with Treasury's
underlying premise. While the FASAB standard does not require the CFS to
include the Statement of Budgetary Resources and Statement of Financing,

10 The CFS has five principal financial statements-the Balance Sheet,
Statement of Net Cost, Statement of Operations and Changes in Net
Position, Reconciliation of Net Operating Cost and Unified Budget Deficit,
and Statement of Changes in Cash Balance from Unified Budget and Other
Activities.

which are required financial statements at the agency level, the standard
should not be interpreted to mean that none of the information reported in
federal agency financial statements is relevant to the Reconciliation of
Net Operating Cost and Unified Budget Deficit and the Statement of Changes
in Cash Balance from Unified Budget and Other Activities. For example,
federal agencies report net outlays in their Statements of Budgetary
Resources, and net outlays for all federal agencies are reflected in the
budget deficit amount reported in the Reconciliation of Net Operating Cost
and Unified Budget Deficit and Statement of Changes in Cash Balance from
Unified Budget and Other Activities in the CFS. During our fiscal year
2004 audit, we identified material differences between net outlays
reported by the agencies and the records used by Treasury to report net
outlays at the consolidated level, totaling about $69 billion.

When differences arise between the amounts Treasury uses to compile the
CFS and related amounts federal agencies are reporting, it is important
for management of the federal government to understand and be able to
explain those differences and take corrective action where needed. For
fiscal year 2004, the Reconciliation of Net Operating Cost and Unified
Budget Deficit and Statement of Changes in Cash Balance from Unified
Budget and Other Activities included some amounts that Treasury could not
explain or fully support or for which Treasury could not demonstrate the
link to agencies' audited financial statements. We continue to believe
that the process of directly linking relevant audited federal agencies'
financial statement information to these two financial statements would be
the most efficient and effective manner for Treasury, as the preparer of
the CFS, to obtain and demonstrate the necessary assurance on certain
information reported in such financial statements. As such, we have not
modified our recommendations in this area.

Treasury stated that it would welcome specific recommendations to address
problems with its Reconciliation of Net Operating Cost and Unified Budget
Deficit and Statement of Changes in Cash Balance from Unified Budget and
Other Activities. In this regard, we have previously provided several
specific recommendations to Treasury regarding the preparation and
reporting of these financial statements, and these recommendations are
included in appendix II of this report.11 Our recommendations are intended
to allow some flexibility in developing viable solutions to address

11 See recommendations 02-12 through 02-21 and 03-4 through 03-7 in
appendix II of this report.

the issues. At the same time, we believe it is crucial that Treasury
develop corrective actions to address our recommendations now as it is
still designing and further implementing its new system and process for
compiling the CFS. Prolonging corrective actions could result in
additional costs to Treasury if it decides later to modify its new system
to collect and compile additional information.

This report contains recommendations to the Secretary of the Treasury and
the Director of OMB. The head of a federal agency is required by 31 U.S.C.
720 to submit a written statement on actions taken on these
recommendations. You should submit your statement to the Senate Committee
on Homeland Security and Governmental Affairs and the House Committee on
Government Reform within 60 days of the date of this report. A written
statement must also be sent to the House and Senate Committees on
Appropriations with the agency's first request for appropriations made
more than 60 days after the date of the report.

We are sending copies of this report to the Chairmen and Ranking Minority
Members of the Senate Committee on Homeland Security and Governmental
Affairs; the Subcommittee on Federal Financial Management, Government
Information, and International Security, Senate Committee on Homeland
Security and Governmental Affairs; the House Committee on Government
Reform; and the Subcommittee on Government Management, Finance, and
Accountability, House Committee on Government Reform. In addition, we are
sending copies to the Fiscal Assistant Secretary of the Treasury and the
Deputy Director for Management of OMB. Copies will be made available to
others upon request. This report is also available at no charge on GAO's
Web site at http://www.gao.gov.

We acknowledge and appreciate the cooperation and assistance provided by
Treasury and OMB during our audit. If you or your staff have any questions
or wish to discuss this report, please contact Jeffrey C. Steinhoff,
Managing Director, Financial Management and Assurance, on (202) 512-2600
or Gary T. Engel, Director, Financial Management and Assurance, on (202)
512-3406.

David M. Walker Comptroller General of the United States

Appendix I

Disclosure Issues

U.S. generally accepted accounting principles (GAAP) require the six
specific disclosures related to three disclosure areas described below to
be included in the consolidated financial statements (CFS), if material.
If management determines that the required disclosures need not be
included, the specific rationale for their exclusion should be
sufficiently documented. However, the Department of the Treasury
(Treasury) neither included the disclosures in the CFS nor provided
documentation with the rationale for exclusion of these required
disclosures.

  Federal Employee and Veteran Benefits Payable

Treasury did not disclose certain required information on the Department
of Veterans Affairs' (VA) insurance benefit liabilities in the CFS. Such
information, as noted below, would include all components of the liability
for future policy benefits with a description of each amount and an
explanation of its projected use and any other potential uses for
noncancelable or renewable VA life insurance.

For noncancelable or renewable VA life insurance, Statement of Federal
Financial Accounting Standards (SFFAS) No. 5, Accounting for Liabilities
of the Federal Government, paragraph 110, table 9, states that all
components of the liability for future policy benefits should be
separately disclosed in a footnote with a description of each amount and
an explanation of its projected use and any other potential uses.

In accordance with SFFAS No. 5, paragraphs 117 and 118, all federal
reporting entities with whole life insurance programs should follow the
standards as prescribed in the private sector standards when reporting the
liability for future policy benefits, in addition to the following
required disclosures: liability for future policy benefits relating to
participating life insurance contracts should be equal to the sum of (1)
the net level premium reserve for death and endowment policy benefits, (2)
the liability for terminal dividends, and (3) any premium deficiency.

Additionally, SFFAS No. 5, paragraph 121, states that all components of
the liability for future policy benefits (i.e., the net-level premium
reserve for death and endowment policy and the liability for terminal
dividends) should be separately disclosed in a footnote with a description
of each amount and an explanation of its projected use and any other
potential uses (e.g., reducing premiums, determining and declaring
dividends available, or reducing federal support in the form of
appropriations related to administrative cost or subsidies).

                          Appendix I Disclosure Issues

The CFS note disclosure for cash and other monetary assets departed from
the disclosure requirements of SFFAS No. 1, Accounting for Selected Assets
and Liabilities, paragraph 30, which requires that financial reports
disclose the reasons for and nature of restricted cash. SFFAS No. 1
defines restricted cash as restrictions usually imposed on cash deposits
(in escrow or other special accounts) by law, regulation, or agreement.
Treasury did not adequately ensure that the note disclosure relating to
Cash and Other Monetary Assets was presented in conformity with GAAP.
Specifically, while agencies are required by Treasury to describe in the
closing package the nature of the amount reported in the line item Other
Cash, they are not required to designate whether such cash is restricted.

In addition, cash held by certain agencies, although not restricted as it
relates to the operations of those agencies, could be legally or otherwise
restricted from a governmentwide perspective. For example, as disclosed by
the Pension Benefit Guaranty Corporation (PBGC), the Employee Retirement
Income Security Act of 1974 and the Pension Protection Act of 1987
established revolving funds in which premiums collected and held are to be
used for specific purposes related to the operations of PBGC. As such, at
the governmentwide level, the cash held by PBGC relating to these
revolving funds could be considered as restricted for governmentwide
reporting purposes. However, Treasury's process did not require agencies
to designate any amounts reported for the "other cash" line items that are
restricted with respect to the federal government taken as a whole.

Other Liabilities	The CFS includes life insurance liabilities in the Other
Liabilities line item. However, the CFS did not report indicators of the
range of uncertainty around insurance-related estimates and the
sensitivity of the estimates to changes in major assumptions, in
accordance with SFFAS No. 5, paragraph 114.

Appendix II

Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

This appendix includes open recommendations from two prior
GAO reports: Financial Audit: Process for Preparing the
Consolidated Financial Statements of the U.S. Government Needs
Improvement, GAO-04-45 (Oct. 30, 2003), and Financial Audit: Process
for Preparing the Consolidated Financial Statements of the
U.S. Government Needs Further Improvement, GAO-04-866 (Sept.
10, 2004). Recommendations that were closed in prior reports are not
included in this appendix. This appendix also includes the status of the
recommendations according to Treasury and the Office of Management and
Budget (OMB) and according to GAO. Explanations are included in the
GAO status of recommendations when Treasury and OMB disagreed with
our recommendation.

Status of recommendations

             Count No. Recommendations Per Treasury and OMB Per GAO

GAO-04-45 (results of the fiscal year 2002 audit)

02-1	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in connection with Treasury's current compilation process and
the development of Treasury's new compilation system and process, to
segregate the duties of individuals who have the capability to enter,
change, and delete data within the Federal Agencies' Centralized Trial
Balance System (FACTS I) and the Hyperion database and post adjustments to
the CFS.

Treasury established significant policies and procedures to segregate
duties with the new fiscal year 2004 process. Treasury is currently
addressing the instances identified by GAO and expects to address this
recommendation completely in fiscal year 2005.

Closed during the fiscal year 2004 audit for FACTS I, but there are
segregation of duties issues with the new process used during fiscal year
2004.

02-2	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in connection with Treasury's current compilation process and
the development of Treasury's new compilation system and process, to
develop and fully document policies and procedures for the CFS preparation
process so that they are proper, complete, and consistently applied by
staff members.

Treasury developed substantial documentation relative to our policies and
procedures for the new fiscal year 2004 process. Treasury is currently
addressing the instances identified by GAO and expects to address this
recommendation completely in fiscal year 2005.

                                     Open.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-4	As Treasury is designing its new financial statement compilation
process to begin with the fiscal year 2004 CFS, the Secretary of the
Treasury should direct the Fiscal Assistant Secretary, in coordination
with the Controller of OMB, to develop reconciliation procedures that will
aid in understanding and controlling the net position balance as well as
eliminate the plugs previously associated with compiling the CFS.

This is a long-standing problem that Treasury will continue analyzing.
However, Treasury designed a process to eliminate intragovernmental
activity and balances using formal balanced accounting entries and
developed a model to provide an analysis of the unreconciled transactions
that affect net position (plug) for fiscal year 2004. Treasury will
further analyze the results of the 2004 process and continue to work on
this issue in 2005 by starting to establish the reciprocal category for
the General Fund and analyzing the changes in net position from the
beginning of the year to the end of the year to eliminate or explain the
adjustments to net position.

                                     Open.

02-5 As Treasury is designing its new   See status of recommendation Open. 
        financial statement compilation    No. 02-4.                    
        process to begin with the fiscal                                
        year                                                            
        2004 CFS, the Secretary of the                                  
        Treasury should direct the Fiscal                               
        Assistant Secretary, in                                         
        coordination                                                    
        with the Controller of OMB, to use                              
        balanced accounting entries to                                  
             account for the change in net                              
                                  position                              
        rather than simple subtraction of                               
        liabilities from assets.                                        

02-6	As OMB continues to make strides to OMB is reviewing the business
rules Open. address issues related to and also performing additional
intragovernmental transactions, the analysis on several groupings of
Director of OMB should direct the intragovernmental transactions. Upon
Controller of OMB to develop policies the conclusion of the review and and
procedures that document how analysis, OMB will determine how OMB will
enforce the business rules best to proceed with the business provided in
OMB Memorandum rules. M-03-01, Business Rules for Intragovernmental
Transactions.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-7	As OMB continues to make strides to OMB and Treasury are performing
Open. address issues related to additional analysis on several
intragovernmental transactions, the groupings of intragovernmental
Director of OMB should direct the transactions and will work with
Controller of OMB to require that individual agencies to resolve
significant differences noted between imbalances. As part of OMB's
business partners be resolved and the standard practice, resolutions
reached resolution be documented. will be communicated to all parties.

02-8	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to implement the
plan to require federal agencies to report in Treasury's new closing
package, beginning with fiscal year 2004, intragovernmental activity and
balances by trading partner and to indicate amounts that have not been
reconciled with trading partners and amounts, if any, that are in dispute.

Treasury is in the process of identifying material differences so that OMB
and Treasury can work with agencies to resolve differences. Also, the
Chief Financial Officers Council Financial Reporting Acceleration
Committee has begun efforts to identify issues and impediments to
intragovernmental reconciliations and recommend solutions to mitigate
those issues.

                                     Open.

02-9 The Secretary of the Treasury       See status of               Open. 
        should                              recommendation              
        direct the Fiscal Assistant         No. 02-4.                   
        Secretary,                                                      
        in coordination with the Controller                             
        of                                                              
        OMB, to design procedures that will                             
        account for the difference in                                   
        intragovernmental assets and                                    
        liabilities throughout the                                      
        compilation                                                     
        process by means of formal                                      
        consolidating and elimination                                   
        accounting entries.                                             

02-10 The Secretary of the Treasury      See status of               Open. 
         should                             recommendation              
         direct the Fiscal Assistant        No. 02-4.                   
         Secretary,                                                     
         in coordination with the                                       
         Controller of                                                  
         OMB, to develop solutions for                                  
         intragovernmental activity and                                 
         balance issues relating to federal                             
         agencies' accounting, reconciling,                             
         and                                                            
         reporting in areas other than                                  
         those                                                          
         OMB now requires be reconciled,                                
         primarily areas relating to                                    
         appropriations.                                                

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-11	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to reconcile the
change in intragovernmental assets and liabilities for the fiscal year,
including the amount and nature of all changes in intragovernmental assets
or liabilities not attributable to cost and revenue activity recognized
during the fiscal year. Examples of these differences would include
capitalized purchases, such as inventory or equipment, and deferred
revenue.

See status of recommendation Open. No. 02-4.

02-12	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to develop and implement a process that adequately identifies
and reports items needed to reconcile net operating cost and unified
budget surplus (or deficit). Treasury should report "net unreconciled
differences" included in the net operating results line item as a separate
reconciling Treasury disagrees with GAO on this item. No further action is
contemplated for this recommendation.

                   activity in the reconciliation statement.

Open. Treasury disagrees with all of our recommendations regarding the
Statement of Changes in Cash Balance from Unified Budget and Other
Activities and the Reconciliations of Net Operating Cost and Unified
Budget Deficit even though these statements include some amounts that
Treasury cannot explain or fully support or for which Treasury cannot
demonstrate that the amounts clearly link to agencies' audited financial
statements. Treasury has not developed any alternative solutions. We
continue to believe that implementation of our recommendations would
result in the most efficient and effective manner for Treasury, as the
preparer of the CFS, to obtain and demonstrate the necessary assurance on
the significant amounts reported in the Statement of Changes in Cash
Balance from Unified Budget and Other Activities and the Reconciliation of
Net Operating Cost and Unified Budget Deficit.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

Count  No.     Recommendations     Per Treasury and         Per GAO        
                                             OMB         
         02-13 The Secretary of the  Treasury disagrees  Open. In fiscal year 
               Treasury should            with GAO       2004, Treasury       
               direct the Fiscal      on this item. No    developed standard  
               Assistant Secretary     further action         operating       
               to develop and        is contemplated for    procedures for    
               implement a process          this            preparing the     
               that adequately                             Reconciliations of 
               identifies and          recommendation.      the Net Operating 
               reports                                   
                  items needed to                          Cost and Budget    
                   reconcile net                             Deficit and      
                operating cost and                       Statement of Changes 
                  unified budget                               in Cash        
               surplus (or deficit).                     Balance from Unified 
               Treasury should                           Budget and           
               develop policies and                       Other Activities.   
                   procedures to                             However, the     
               ensure completeness                        procedures merely   
               of reporting and                              covered the      
               document how all the                      source of the        
                    applicable                           information, with no 
                components reported                      process for ensuring 
                   in the other                                  that         
                   consolidated                               (1) information 
               financial statements                      obtained was correct 
               (and related note                          and consistent with 
               disclosures included                         underlying agency 
               in the CFS) were                          audited financial    
               properly reflected in                     statements and       
                the reconciliation                        (2) reporting was   
                    statement.                                complete.       

02-14	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to develop and implement a process that adequately identifies
and reports items needed to reconcile net operating cost and unified
budget surplus (or deficit). Treasury should establish reporting
materiality thresholds for determining which agency financial statement
activities to collect and report at the governmentwide level to assist in
ensuring that the reconciliation statement is useful and conveys
meaningful information.

Treasury disagrees with GAO Open. The standard operating on this item. No
further action procedures that Treasury developed is contemplated for this
did not include considerations for recommendation. materiality thresholds
in its financial

reporting or reconciling activities.

02-15 If Treasury chooses to   Treasury disagrees with Open. See status of 
         continue using                     GAO                recommendation 
          information from both      on this item. No         No. 02-12.      
                 federal              further action      
         agencies' financial        is contemplated for   
         statements and the                this           
          Central Accounting and      recommendation.     
                Reporting                                 
         System (STAR), Treasury                          
                  should                                  
         demonstrate how the                              
         amounts from                                     
         STAR reconcile to                                
         federal agencies'                                
          financial statements.                           

15 02-16 If Treasury chooses to    Treasury disagrees  Open. See status of 
            continue using                 with GAO            recommendation 
              information from both    on this item. No       No. 02-12.      
                     federal            further action    
               agencies' financial    is contemplated for 
                 statements and              this         
            from STAR, Treasury         recommendation.   
            should identify                               
            and document the cause of                     
                       any                                
            significant differences,                      
                   if any are                             
                     noted.                               

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-17	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to develop and
implement a process to ensure that the Statement of Changes in Cash
Balance from Unified Budget and Other Activities properly reflects
theactivities reported in federal agencies' audited financial statements.
Treasury should document the consistency of the significant line items on
this statement to agencies' audited financial statements.

Treasury disagrees with GAO on this item. This statement is not prepared
from the agency's financial statements. As cited in GAO-04-866,

p. 44, #3, para. 3: "It is important to note that the "information"
[referred to in SFFAS 24, 9. SFFAS 7, paras. 77

82] is not required therefore agency budgetary data is not used nor was
ever contemplated to be used in our reports. Treasury maintains the source
of original entry for budgetary information in the STAR system and
consider the use of other data not only less accurate but also a waste of
taxpayer resources to both obtain and then correct the balances when
Treasury already has the information at their finger tips. There are no
material differences between outlays reported by us and those included in
the President's Budget. The standard does not require either receipts or
outlays."

Open. See status of recommendation No. 02-12.

02-18	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to develop and
implement a process to ensure that the Statement of Changes in Cash
Balance from Unified Budget and Other Activities properly reflects
theactivities reported in federal agencies' audited financial statements.
Treasury should request, through its closing package, that federal
agencies provide the net outlays reported in their Combined Statement of
Budgetary Resources and explanations for any significant differences
between net outlay amounts reported in the Combined Statement of Budgetary
Resources and the budget of the U.S. government.

Treasury disagrees with GAO's recommendation to collect the agency
Statement of Budgetary Resources outlay data through the Closing Package
process because Treasury already collects agency outlay data for budgetary
reporting purposes. Treasury and OMB are working closely with the agencies
to assure that the outlays reported in their Statement of Budgetary
Resources match the outlays reported to Treasury for budgetary reporting
purposes.

Open. See status of recommendation No. 02-12.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-19	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to develop and
implement a process to ensure that the Statement of Changes in Cash
Balance from Unified Budget and Other Activities properly reflects
theactivities reported in federal agencies' audited financial statements.
Treasury should investigate the differences between net outlays reported
in federal agencies' Combined Statement of Budgetary Resources and
Treasury's records in STAR to ensure that the proper amounts are reported
in the Statement of Changes in Cash Balance from Unified Budget and Other
Activities.

See status of recommendation Open. Material unexplained

No. 02-18.	differences between net outlays reported by the agencies and
the central accounting records used to report net outlays at the
consolidated level remained, totaling about $69 billion in fiscal year
2004.

02-20	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to develop and
implement a process to ensure that the Statement of Changes in Cash
Balance from Unified Budget and Other Activities properly reflects
theactivities reported in federal agencies' audited financial statements.
Treasury should explain and document the differences between the operating
revenue amount reported on the Statement of Operations and Changes in Net
Position and unified budget receipts reported on the Statement of Changes
in Cash Balance from Unified Budget and Other Activities.

See status of recommendation Open. In fiscal year 2004, there was a

No. 02-17.	$34.5 billion unexplained or unreported difference between the
unified budget receipts as a component of the deficit and the modified
cash operating revenue on the Statement of Operations and Changes in Net
Position.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-21	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to develop and
implement a process to ensure that the Statement of Changes in Cash
Balance from Unified Budget and Other Activities properly reflects
theactivities reported in federal agencies' audited financial statements.
Treasury should provide support for how the line items in the "other
activities" section of this statement relate to either the underlying
Balance Sheet or related notes accompanying the CFS.

Treasury disagrees with GAO Open. See status of recommendation on this
item. However, further No. 02-12. research and discussion will take place
in fiscal year 2005.

02-22	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to perform an
assessment to define the reporting entity, including its specific
components, in conformity with the criteria issued by the Federal
Accounting Standards Advisory Board. Key decisions made in this assessment
should be documented, including the reason for including or excluding
components and the basis for concluding on any issue. Particular emphasis
should be placed on demonstrating that any financial information that
should be included but is not included is immaterial.

Treasury's Office of the Fiscal Assistant Secretary (OFAS) has developed
an action plan for defining the reporting entity. Treasury will determine
the relevant information not currently received, and the Financial
Management Service will implement changes OFAS identifies.

                                     Open.

02-23 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-22.                   
         Secretary,                                                     
         in coordination with the                                       
         Controller of                                                  
         OMB, to provide in the financial                               
         statements all the financial                                   
         information relevant to the                                    
         defined                                                        
         reporting entity, in all material                              
         respects. Such information would                               
         include, for example, the                                      
         reporting                                                      
         entity's assets, liabilities, and                              
         revenues.                                                      

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-24	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to disclose in the
financial statements all information that is necessary to inform users
adequately about the reporting entity. Such disclosures should clearly
describe the reporting entity and explain the reason for excluding any
components that are not included in the defined reporting entity.

See status of recommendation Open. No. 02-22.

02-25	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to establish a formal process that will allow the financial
statements, related notes, and stewardship and supplemental information in
the CFS to be presented in conformity with GAAP. The process should timely
identify GAAP requirements.

Treasury developed and documented a process to compare federal accounting
standards and the closing package to ensure that all disclosures are
requested from federal agencies. Treasury is currently analyzing the
reporting and modifying the CFS to include GAAP requirements. Treasury
expects to address the majority of these items in the 2005 CFS by
including the appropriate disclosures in the CFS or documenting the
rationale for excluding inappropriate disclosures.

                                     Open.

02-26 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to establish a formal process                                  
         that will                                                      
         allow the financial statements,                                
         related                                                        
         notes, and stewardship and                                     
         supplemental information in the                                
         CFS                                                            
         to be presented in conformity                                  
         with                                                           
         GAAP. The process should make                                  
         timely modifications to                                        
         Treasury's                                                     
         closing package requirements to                                
         obtain information needed.                                     

26 02-27 The Secretary of the Treasury    See status of              Open. 
            should                           recommendation             
            direct the Fiscal Assistant      No. 02-25.                 
            Secretary                                                   
            to establish a formal process                               
            that will                                                   
            allow the financial statements,                             
            related                                                     
            notes, and stewardship and                                  
            supplemental information in the                             
            CFS                                                         
            to be presented in conformity                               
            with                                                        
            GAAP. The process should assess,                            
            qualitatively and                                           
            quantitatively, the                                         
            impact of the omitted                                       
            disclosures.                                                

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-28 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to establish a formal process                                  
         that will                                                      
         allow the financial statements,                                
         related                                                        
         notes, and stewardship and                                     
         supplemental information in the                                
         CFS                                                            
         to be presented in conformity                                  
         with                                                           
         GAAP. The process should document                              
         decisions reached and the                                      
         rationale                                                      
         for such decisions.                                            

02-29	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures for preparing the governmentwide
management representation letter to help ensure that it is properly
prepared and contains sufficient representations. Specifically, these
policies and procedures should require an analysis of the agency
management representations to determine if discrepancies exist between
what the agency auditor reported and the representations made by the
agency, including the resolution of such discrepancies.

Discussions are ongoing with GAO as Open.
to the use of the agencies'
management representation letters,
supplemented with other procedures.

02-30	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures for preparing the governmentwide
management representation letter to help ensure that it is properly
prepared and contains sufficient representations. Specifically, these
policies and procedures should require a determination that the agency
management representation letters have been signed by the highest-level
agency officials who are responsible for and knowledgeable about the
matters included in the agency management representation letters.

Treasury and OMB's policy includes the following sentence: "Items included
or not included in the agencies' rep letters will generally not be
challenged by Treasury and OMB since they were obviously not a factor in
that agency's audit and, therefore, should not then rise to the
consolidated governmentwide audit level." Discussions are ongoing with GAO
as to the use of the agencies' management representation letters,
supplemented with other procedures.

Open. The policies and procedures discuss signatures on agency management
representation letters, but do not include steps for Treasury's review of
the signatures to determine if the letters have been signed by the
highest-level agency officials who are responsible for and knowledgeable
about the matters included in the agency management representation
letters.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

30 02-31 The Secretary of the Treasury should When preparing the           
            governmentwide Open. In the fiscal years 2003 and                 
            direct the Fiscal Assistant Secretary, management representation  
            letter, 2004 audits, we reported a limitation                     
               in coordination with the Controller of Treasury follows the    
                       guidance in on the scope of our work due to            
                 OMB, to establish written policies and GAO's Financial Audit 
                           Manual (FAM) identified concerns with the adequacy 
                 procedures for preparing the to calculate an amount for      
                        materiality. of certain federal agencies'             
              governmentwide management The FAM is GAO's guidance for those   
                             management representations, on                   
            representation letter to help ensure entities that are performing 
            audits of which Treasury and OMB depend to                        
            that it is properly prepared and federal entities. Treasury then  
            provide their representations to us                               
            contains sufficient representations. executes the following step, 
            which is regarding the CFS. These concerns                        
            Specifically, these policies and written in Treasury and OMB's    
            policy: included the omission of materiality                      
                procedures should require an "We check to ensure that the     
                              thresholds. The policies and                    
            assessment of the materiality materiality amounts cited by those  
            procedures do not include steps to                                
                 thresholds used by federal agencies in agencies who do       
                      quantitatively obtain and assess materiality            
            their respective management discuss materiality are not larger    
            than thresholds from agencies that do not                         
                      representation letters. the materiality cited in the FR 
                                     quantitatively cite the amounts in their 
                 management representation letter." management representation 
                                                                     letters. 

02-32	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures for preparing the governmentwide
management representation letter to help ensure that it is properly
prepared and contains sufficient representations. Specifically, these
policies and procedures should require an assessment of the impact, if
any, of federal agencies' materiality thresholds on the management
representations made at the governmentwide level.

When preparing the governmentwide management representation letter,
Treasury follows the guidance in GAO's FAM to calculate an amount for
materiality. The FAM is GAO's guidance for those entities that are
performing audits of federal entities. Treasury then executes the
following step, which is written in Treasury and OMB's policy: "We check
to ensure that the materiality amounts cited by those agencies who do
quantitatively discuss materiality are not larger than the materiality
cited in the FR management representation letter."

Open. In the fiscal years 2003 and 2004 audits, we reported a limitation
on the scope of our work due to identified concerns with the adequacy of
certain federal agencies' management representations, on which Treasury
and OMB depend to provide their representations to us regarding the CFS.
These concerns included the omission of materiality thresholds. The
policies and procedures do not include steps to obtain and assess
materiality thresholds from agencies that do not quantitatively cite the
amounts in their management representation letters. In addition, the
policies and procedures are not sufficient to assess the impact of
agencies' materiality thresholds on the management representations made at
the governmentwide level.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

02-33	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures for preparing the governmentwide
management representation letter to help ensure that it is properly
prepared and contains sufficient representations. Specifically, these
policies and procedures should require an evaluation and assessment of the
omission of representations ordinarily included in agency management
representation letters.

Treasury and OMB's policy includes the following sentence: "Items included
or not included in the agencies' rep letters will generally not be
challenged by Treasury and OMB since they were obviously not a factor in
that agency's audit and, therefore, should not then rise to the
consolidated governmentwide audit level." Discussions are ongoing with GAO
as to the use of the agencies' management representation letters,
supplemented with other procedures.

Open. In the fiscal years 2003 and 2004 audits, we reported a limitation
on the scope of our work due to identified concerns with the adequacy of
certain federal agencies' management representations, on which Treasury
and OMB depend to provide their representations to us regarding the CFS.
These concerns included the omission and incompleteness of required
representations. The policies and procedures do not include steps to
review the agencies' management representation letters for omitted or
incomplete representations. In addition, the policies and procedures do
not include steps to assess the impact of omitted or incomplete
representations on the governmentwide management representation letter.

02-34	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures for preparing the governmentwide
management representation letter to help ensure that it is properly
prepared and contains sufficient representations. Specifically, these
policies and procedures should require an analysis and aggregation of the
agencies' summary of unadjusted misstatements to determine the
completeness of the summaries and to ascertain the materiality, both
individually and in the aggregate, of such unadjusted misstatements to the
CFS taken as a whole.

Financial Management Service is currently updating the standard operating
procedures for the summaries of unadjusted misstatements.

Open. In the fiscal years 2003 and 2004 audits, we reported a limitation
on the scope of our work due to identified concerns with the adequacy of
certain federal agencies' management representations, on which Treasury
and OMB depend to provide their representations to us regarding the CFS.
These concerns included the omission and incompleteness of the summaries
of unadjusted misstatements, which are, attached to the agencies
management representation letters. The policies and procedures do not
include steps to ensure that all summaries of unadjusted misstatements
have been received from the agencies. In addition, the policies and
procedures do not include steps to obtain information missing from
summaries submitted by the agencies in order to adequately prepare the
governmentwide summary of unadjusted misstatements.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-35	The Secretary of the Treasury should OMB and Treasury will work to
ensure Open. direct the Fiscal Assistant Secretary, that adequate
information is provided in coordination with the Controller of in the
legal representation letters OMB, to help ensure that agencies regarding
the expected outcome of provide adequate information in their cases. legal
representation letters regarding the expected outcome of the cases.

02-36	The Secretary of the Treasury should OMB and Treasury will follow up
with Open. direct the Fiscal Assistant Secretary, agencies that have not
provided their in coordination with the Controller of management schedules
to ensure OMB, to help ensure that agencies they do so. provide related
management schedules.

02-37	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures to help ensure that major treaty and other
international agreement information is properly identified and reported in
the CFS. Specifically, these policies and procedures should require that
agencies develop a detailed schedule of all major treaties and other
international agreements that obligate the U.S. government to provide
cash, goods, or services, or that create other financial arrangements that
are contingent on the occurrence or nonoccurrence of future events (a
starting point for compiling these data could be the State Department's
Treaties in Force).

OMB will analyze the appropriateness Open. of reporting "treaties" before
developing specific corrective actions.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-38	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures to help ensure that major treaty and other
international agreement information is properly identified and reported in
the CFS. Specifically, these policies and procedures should require that
agencies classify all such scheduled major treaties and other
international agreements as commitments or contingencies.

OMB will analyze the appropriateness Open. of reporting "treaties" before
developing specific corrective actions.

02-39	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures to help ensure that major treaty and other
international agreement information is properly identified and reported in
the CFS. Specifically, these policies and procedures should require that
agencies disclose in the notes to the CFS amounts for major treaties and
other international agreements that have a reasonably possible chance of
resulting in a loss or claim as a contingency.

OMB will analyze the appropriateness Open. of reporting "treaties" before
developing specific corrective actions.

02-40	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures to help ensure that major treaty and other
international agreement information is properly identified and reported in
the CFS. Specifically, these policies and procedures should require that
agencies disclose in the notes to the CFS amounts for major treaties and
other international agreements that are classified as commitments and that
may require measurable future financial obligations.

OMB will analyze the appropriateness Open. of reporting "treaties" before
developing specific corrective actions.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-41	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to establish
written policies and procedures to help ensure that major treaty and other
international agreement information is properly identified and reported in
the CFS. Specifically, these policies and procedures should require that
agencies take steps to prevent major treaties and other international
agreements that are classified as remote from being recorded or disclosed
as probable or reasonably possible in the CFS.

OMB will analyze the appropriateness Open. of reporting "treaties" before
developing specific corrective actions.

41 02-42      As Treasury is designing its new Treasury developed and      
                      implemented Open. Treasury's goal for the new           
                compilation process, which it expects the new compilation     
                   process, which system is to directly link financial        
              to implement beginning with the fiscal directly links agency    
                  audited financial information from federal agencies'        
            year 2004 CFS, the Secretary of the statements to the CFS except  
                           for audited financial statements to                
            Treasury should direct the Fiscal Reconciliation of Net Operating 
                           Cost amounts reported in the CFS, a                
            Assistant Secretary, in coordination and Statements of Changes in 
                         Cash concept that we strongly support.               
              with the Controller of OMB, to design Balance for fiscal year   
                    2004. For fiscal However, based on our review of          
                  the new compilation process to year 2005, for completeness, 
                                Treasury Treasury's new process, Treasury was 
                  directly link information from federal will establish       
                 traceability from agency unable to demonstrate that the      
                     agencies' audited financial statements audited financial 
                   statement footnotes information in the CFS directly linked 
            to amounts reported in all the to the CFS footnotes. to agencies' 
                                    audited financial                         
                    applicable CFS and related footnotes. statements.         

02-43	As Treasury is designing its new compilation process, which it
expects to implement beginning with the fiscal year 2004 CFS, the
Secretary of the Treasury should direct the Fiscal Assistant Secretary, in
coordination with the Controller of OMB, to consider the other applicable
recommendations in this report when designing and implementing the new
compilation process.

Treasury will continue to consider Open. applicable recommendations as the
new compilation system is enhanced.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-44	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of Statement of Federal
Financial Accounting Standards (SFFAS) No. 3,

Accounting for Inventory and Related Property, paragraph 91, which
requires the reporting entity to disclose the valuation basis for
foreclosed property.

See status of recommendation Open. No. 02-25.

02-45 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         loans receivable and loan                                      
         guarantee                                                      
         liabilities meets the                                          
         requirements of                                                
         SFFAS No. 3, Accounting for                                    
         Inventory and Related Property,                                
         paragraph 91, which requires the                               
         reporting entity to disclose the                               
         changes from the prior year's                                  
         accounting methods, if any.                                    

02-46 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         loans receivable and loan                                      
         guarantee                                                      
         liabilities meets the                                          
         requirements of                                                
         SFFAS No. 3, Accounting for                                    
         Inventory and Related Property,                                
         paragraph 91, which requires the                               
         reporting entity to disclose the                               
         restrictions on the use/disposal                               
         of                                                             
         property.                                                      

02-47 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         loans receivable and loan                                      
         guarantee                                                      
         liabilities meets the                                          
         requirements of                                                
         SFFAS No. 3, Accounting for                                    
         Inventory and Related Property,                                
         paragraph 91, which requires the                               
         reporting entity to disclose the                               
         balances by categories (i.e.,                                  
         pre-1992                                                       
         and post-1991 foreclosed                                       
         property).                                                     

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-48 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         loans receivable and loan                                      
         guarantee                                                      
         liabilities meets the                                          
         requirements of                                                
         SFFAS No. 3, Accounting for                                    
         Inventory and Related Property,                                
         paragraph 91, which requires the                               
         reporting entity to disclose the                               
         number                                                         
         of properties held and average                                 
         holding period by type or                                      
         category.                                                      

02-49	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 3, Accounting
for Inventory and Related Property, paragraph 91, which requires the
reporting entity to disclose the number of properties for which
foreclosure proceedings are in process at the end of the period for
foreclosed assets acquired in full or partial settlement of a direct or
guaranteed loan.

See status of recommendation Open. No. 02-25.

02-50	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph 9,
which requires credit programs to reestimate the subsidy cost allowance
for outstanding direct loans and the liability for outstanding loan
guarantees. There are two kinds of reestimates: (1) interest rate
reestimates and (2) technical/default reestimates. Entities should measure
and disclose each program's reestimates in these two components
separately.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-51	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
10, which requires the reporting entity to display in the notes to the
financial statements a reconciliation between the beginning and ending
balances of the subsidy cost allowance for outstanding direct loans and
the liability for outstanding loan guarantees reported on the entity's
balance sheet.

See status of recommendation Open. No. 02-25.

02-52	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
11, which requires disclosure of the total amount of direct or guaranteed
loans disbursed for the current reporting year and the preceding reporting
year.

See status of recommendation Open. No. 02-25.

02-53	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
11, which requires disclosure of the subsidy expense by components,
recognized for the direct or guaranteed loans disbursed in the current
reporting year and the preceding reporting year.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-54	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
11, which requires disclosure of the subsidy reestimates by components for
the current reporting year and the preceding reporting year.

See status of recommendation Open. No. 02-25.

02-55	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
11, which requires disclosure, at the program level, of the subsidy rates
for the total subsidy cost and its components for the interest subsidy
costs, default costs (net of recoveries), fees and other collections, and
other costs estimated for direct loans and loan guarantees in the current
year's budget for the current year's cohorts.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-56	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for loans receivable and loan
guarantee liabilities meets the requirements of SFFAS No. 18, Amendments
to Accounting Standards for Direct Loans and Loan Guarantees, paragraph
11, which requires the reporting entity to disclose, discuss, and explain
events and changes in economic conditions, other risk factors,
legislation, credit policies, and subsidy estimation methodologies and
assumptions that have had a significant and measurable effect on subsidy
rates, subsidy expense, and subsidy reestimates.

See status of recommendation Open. No. 02-25.

02-57	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for inventories and operating
materials and supplies meets the requirements of SFFAS No. 3, Accounting
for Inventory and Related Property, paragraph 30, which requires the
difference between the carrying amount and the expected net realizable
value to be recognized as a loss or gain and either separately reported or
disclosed when inventory or operating materials and supplies are declared
excess, obsolete, or unserviceable.

See status of recommendation Open. No. 02-25.

02-58 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         inventories and operating                                      
         materials                                                      
         and supplies meets the                                         
         requirements                                                   
         of SFFAS No. 3, Accounting for                                 
         Inventory and Related Property,                                
         paragraphs 35 and 50, which                                    
         require                                                        
         disclosure of inventory and                                    
         operating                                                      
         materials and supplies general                                 
         composition.                                                   

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-59	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for inventories and operating
materials and supplies meets the requirements of SFFAS No. 3, Accounting
for Inventory and Related Property, paragraphs 35 and 50, that require
disclosure of any changes from the prior year in accounting methods for
inventory and operating materials and supplies.

See status of recommendation Open. No. 02-25.

02-60 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         inventories and operating                                      
         materials                                                      
         and supplies meets the                                         
         requirements                                                   
         of SFFAS No. 3, Accounting for                                 
         Inventory and Related Property,                                
         paragraphs 35 and 50, which                                    
         require                                                        
         the disclosure of any                                          
         restrictions on                                                
         the sale of inventory and the use                              
         of                                                             
         operating materials and supplies.                              

02-61 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         inventories and operating                                      
         materials                                                      
         and supplies meets the                                         
         requirements                                                   
         of SFFAS No. 3, Accounting for                                 
         Inventory and Related Property,                                
         paragraphs 35 and 50, which                                    
         requires                                                       
         disclosure of any changes in the                               
         criteria for categorizing                                      
         inventory and                                                  
         operating materials and supplies.                              

02-62 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of the basis                               
         for                                                            
         valuing stockpile material,                                    
         including                                                      
         valuation method and any cost                                  
         flow                                                           
         assumptions.                                                   

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-63 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of any                                     
         changes                                                        
         from the prior year's accounting                               
         methods.                                                       

02-64 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of                                         
         restrictions on                                                
         the use of stockpile material.                                 

02-65 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of the                                     
         balances in                                                    
         each category of stockpile                                     
         material                                                       
         (i.e., stockpile material held                                 
         and held                                                       
         for sale).                                                     

02-66 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of the                                     
         criteria for                                                   
         grouping stockpile material held                               
         for sale.                                                      

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-67 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 56, which                                  
         requires disclosure of changes in                              
         criteria for categorizing                                      
         stockpile                                                      
         material held for sale.                                        

02-68 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         stockpile material meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 55, which                                  
         requires disclosure of any                                     
         difference                                                     
         between the carrying amount                                    
         (i.e.,                                                         
         purchase price or cost) of                                     
         stockpile                                                      
         material held for sale and the                                 
           estimated selling price of such                              
                                   assets.                              

02-69 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         seized material meets the                                      
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 66, which                                  
         requires disclosure of the                                     
         valuation                                                      
         method.                                                        

02-70 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         seized material meets the                                      
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 66, which                                  
         requires disclosure of any                                     
         changes                                                        
         from the prior year's accounting                               
         methods.                                                       

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-71	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for seized material meets the
requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 66, which
requires disclosure of the analysis of change in seized property
(including dollar value and number of seized properties) that is on hand
at the beginning of the year, seized during the year, disposed of during
the year, and on hand at the end of the year, as well as known liens or
other claims against the property. This information should be presented by
type of seizure and method of disposition, when material.

See status of recommendation Open. No. 02-25.

02-72 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         forfeited property meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 78, which                                  
         requires disclosure of the                                     
         valuation                                                      
         method.                                                        

02-73	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for forfeited property meets
the requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 78, which
requires disclosure of the analysis of the changes in forfeited property
by type and dollar amount that includes (1) number of forfeitures on hand
at the beginning of the year, (2) additions, (3) disposals and method of
disposition, and (4) end-ofyear balances.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-74 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         forfeited property meets the                                   
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 78, which                                  
         requires disclosure of any                                     
         restriction                                                    
         on the use or disposition of the                               
         property.                                                      

02-75	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for forfeited property meets
the requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 78, which
requires disclosure, if available, of an estimate of the value of property
to be distributed to other federal, state, and local agencies in future
reporting periods.

See status of recommendation Open. No. 02-25.

02-76	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for goods held under price
support and stabilization programs meets the requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 98, which
requires that if a contingent loss is not recognized because it is less
than probable or it is not reasonably measurable, disclosure of the
contingency shall be made if it is at least reasonably possible that a
loss may occur.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-77	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for goods held under price
support and stabilization programs meets the requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 109, which
requires disclosure of the basis for valuing commodities, including
valuation method and cost flow assumptions.

See status of recommendation Open. No. 02-25.

02-78 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         goods held under price support                                 
         and                                                            
         stabilization programs meets the                               
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 109, which                                 
         requires disclosure of any                                     
         changes                                                        
         from the prior year's accounting                               
         methods.                                                       

02-79 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         goods held under price support                                 
         and                                                            
         stabilization programs meets the                               
         requirements of SFFAS No. 3,                                   
         Accounting for Inventory and                                   
         Related                                                        
         Property, paragraph 109, which                                 
         requires disclosure of any                                     
         restrictions                                                   
         on the use, disposal, or sale of                               
         commodities.                                                   

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-80	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for goods held under price
support and stabilization programs meets the requirements of SFFAS No. 3,

Accounting for Inventory and Related Property, paragraph 109, which
requires disclosure of the analysis of the change in dollar amount and
volume of commodities, including those (1) on hand at the beginning of the
year, (2) acquired during the year, (3) disposed of during the year listed
by method of disposition, (4) on hand at the end of the year, (5) on hand
at year-end and estimated to be donated or transferred during the coming
period, and (6) received as a result of surrender of collateral related to
nonrecourse loans outstanding. The analysis should also show the dollar
value and volume of purchase agreement commitments.

See status of recommendation Open. No. 02-25.

02-81 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         property, plant, and equipment                                 
         (PP&E) meets the disclosure                                    
         requirements of SFFAS No. 6,                                   
         Accounting for Property, Plant,                                
         and                                                            
         Equipment, paragraph 45, which                                 
         requires disclosure of the                                     
         estimated                                                      
         useful lives for each major class                              
         of                                                             
         PP&E.                                                          

02-82 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         PP&E meets the disclosure                                      
         requirements of SFFAS No. 6,                                   
         Accounting for Property, Plant,                                
         and                                                            
         Equipment, paragraph 45, which                                 
         requires disclosure of                                         
         capitalization                                                 
         thresholds, including any changes                              
         in                                                             
         thresholds during the period.                                  

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-83 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         PP&E meets the disclosure                                      
         requirements of SFFAS No. 6,                                   
         Accounting for Property, Plant,                                
         and                                                            
         Equipment, paragraph 45, which                                 
         requires disclosure of                                         
         restrictions on                                                
         the use or convertibility of                                   
         general                                                        
         PP&E.                                                          

02-85 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         PP&E meets the disclosure                                      
         requirements of SFFAS No. 10,                                  
         Accounting for Internal Use                                    
         Software,                                                      
         paragraph 35, which requires                                   
         disclosure of the estimated                                    
         useful life                                                    
         for each major class of software                               
         for                                                            
         internal use software.                                         

02-86 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         PP&E meets the disclosure                                      
         requirements of SFFAS No. 10,                                  
         Accounting for Internal Use                                    
         Software,                                                      
         paragraph 35, which requires                                   
         disclosure of the method of                                    
         amortization for internal use                                  
         software.                                                      

02-87	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for PP&E meets the disclosure
requirements of SFFAS No. 16,

Amendments to Accounting for Property, Plant, and Equipment, paragraph 9,
which requires an appropriate PP&E note disclosure to explain that
"physical quantity" information for the multiuse heritage assets is
included in supplemental stewardship reporting for heritage assets.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-88	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for federal employee and
veteran benefits payable is completely and properly reported,
specifically, that (1) it include a line for the valuation of plan
amendments that occurred during the year and (2) the liability for
military pensions and note disclosure related to the "change in actuarial
accrued pension liability and components of related expenses" agree with
the information presented in the Department of Defense's financial
statements.

See status of recommendation Open. No. 02-25.

02-89	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for environmental and
disposal liabilities meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, which requires (1) estimation and
recognition of cleanup costs associated with general PP&E at the time the
PP&E is placed in service and (2) recognition of a liability for the
portion of the estimated total cleanup cost attributable to that portion
of the physical capacity used or that portion of the estimated useful life
that has passed since the general PP&E was placed in service.

See status of recommendation Open. No. 02-25.

02-90 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         environmental and disposal                                     
         liabilities                                                    
         meets the requirements of SFFAS                                
         No. 6, Accounting for Property,                                
         Plant,                                                         
         and Equipment, which requires                                  
         inclusion of material changes in                               
         total                                                          
         estimated cleanup costs due to                                 
         changes in laws, technology, or                                
         plans.                                                         

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-91	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for capital leases meets the
requirements of Federal Accounting Standards Board (FASB), Statement of
Financial Accounting Standards (SFAS) No. 13, Accounting for Leases,
paragraph 16, which requires future minimum lease payments as of the date
of the latest balance sheet presented, in the aggregate and for each of
the 5 succeeding fiscal years, with separate deductions from the total for
the amount representing executory costs, including any profit thereon,
included in the minimum lease payments, and for the amount of the imputed
interest necessary to reduce the net minimum lease payments to present
value.

See status of recommendation Open. No. 02-25.

02-92 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure for                                                 
         capital leases meets the                                       
         requirements                                                   
         of FASB, SFAS No. 13, Accounting                               
         for                                                            
         Leases, paragraph 16, which                                    
         requires                                                       
         a summary of assets under capital                              
         lease by major asset category and                              
         the                                                            
         related total accumulated                                      
         amortization.                                                  

02-93	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for capital leases meets the
requirements of FASB, SFAS No. 13, Accounting for Leases, paragraph 16,
which requires a general description of the lessee's leasing arrangements,
including but not limited to (1) the basis on which contingent rental
payments are determined; (2) the existence and terms of renewal or
purchase options and escalation clauses; and (3) restrictions imposed by
lease agreements, such as those concerning dividends, additional debt, and
further leasing.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-94	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for life insurance
liabilities meets the requirements of SFFAS No. 5,

Accounting for Liabilities of the Federal Government, paragraph 117, which
requires all federal reporting entities with whole life insurance programs
to follow applicable standards as prescribed in the private sector
standards when reporting the liability for future policy benefits: FASB
SFAS No. 60, Accounting and Reporting by Insurance Enterprises; SFAS No.
97, Accounting and Reporting by Insurance Enterprises for Certain
Long-Duration Contracts and for Realized Gains and Losses from the Sale of
Investments; SFAS No. 120, Accounting and Reporting by Mutual Life
Insurance Enterprises and by Insurance Enterprises for Certain
Long-Duration Participating Contracts; and American Institute of Certified
Public Accountants Statement of Position 95-1,

Accounting for Certain Insurance

Activities of Mutual Life Insurance

Enterprises.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-95	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for life insurance
liabilities meets the requirements of SFFAS No. 5,

Accounting for Liabilities of the Federal Government, paragraph 5, which
requires all components of the liability for future policy benefits (i.e.,
the net-level premium reserve for death and endowment policies and the
liability for terminal dividends) to be separately disclosed in a footnote
with a description of each amount and an explanation of its projected use
and any other potential uses (e.g., reducing premiums, determining and
declaring dividends available, and reducing federal support in the form of
appropriations related to administrative cost or subsidies).

See status of recommendation Open. No. 02-25.

02-96 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure on                                                  
         major commitments and                                          
         contingencies is consistent with                               
         disclosed information in                                       
         individual                                                     
         agencies' financial statements.                                

02-97 The Secretary of the Treasury     See status of recommendation Open. 
         should                                                         
         direct the Fiscal Assistant       No. 02-25.                   
         Secretary                                                      
         to ensure that the note                                        
         disclosure on                                                  
         major commitments and                                          
         contingencies discloses                                        
         sufficient                                                     
         information (detailed discussion)                              
         regarding certain major                                        
         commitments                                                    
         and contingencies.                                             

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-99	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for collections and refunds
of federal revenue meets the requirements of SFFAS No. 7, Concepts for
Reconciling Budgetary and Financial Accounting, paragraph 69.2, which
requires collecting entities to provide in the other accompanying
information any relevant estimates of the annual tax gap that become
available as a result of federal government surveys or studies.

See status of recommendation Open. No. 02-25.

02-100	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for dedicated collections
meets the requirements of SFFAS No. 7, Part I,

Accounting for Revenue and Other Financing Sources, paragraph 85, which
requires inclusion of condensed information about assets and liabilities
showing investments in Treasury securities, other assets, liabilities due
and payable to beneficiaries, other liabilities, and fund balance.

See status of recommendation Open. No. 02-25.

02-101	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for dedicated collections
meets the requirements of SFFAS No. 7, Part I,

Accounting for Revenue and Other Financing Sources, paragraph 85, which
requires inclusion of condensed information on net cost and changes to
fund balance, showing revenues by type (exchange/nonexchange), program
expenses, other expenses, other financing sources, and other changes in
fund balance.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

02-102	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for dedicated collections
meets the requirements of SFFAS No. 7, Part I,

Accounting for Revenue and Other Financing Sources, paragraph 85, which
requires inclusion of any revenues, other financing sources, or costs
attributable to the fund under accounting standards but not legally
allowable as credits or charges to the fund.

See status of recommendation Open. No. 02-25.

100 02-103	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for Indian trust
funds meets the requirements of SFFAS No. 7, Part I, Accounting for
Revenue and Other Financing Sources, paragraph 85, which requires a
description of each fund's purpose, how the administrative entity accounts
for and reports the fund, and its authority to use those collections.

See status of recommendation Open. No. 02-25.

101 02-104	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for Indian trust
funds meets the requirements of SFFAS No. 7, Part I, Accounting for
Revenue and Other Financing Sources, paragraph 85, which requires
disclosure of the sources of revenue or other financing for the period and
an explanation of the extent to which they are inflows of resources to the
government or the result of intragovernmental flows.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

102 02-105	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for Indian trust
funds meets the requirements of SFFAS No. 7, Part I, Accounting for
Revenue and Other Financing Sources, paragraph 85, which requires
condensed information about assets and liabilities showing investments in
Treasury securities, other assets, liabilities due and payable to
beneficiaries, and other liabilities.

See status of recommendation Open. No. 02-25.

103 02-106	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for Indian trust
funds meets the requirements of SFFAS No. 7, Part I, Accounting for
Revenue and Other Financing Sources, paragraph 85, which requires
condensed information on net cost and changes to fund balance, showing
revenues by type (exchange/nonexchange), program expenses, other expenses,
other financing sources, and other changes in fund balance.

See status of recommendation Open. No. 02-25.

104 02-107	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for Indian trust
funds meets the requirements of SFFAS No. 7, Part I, Accounting for
Revenue and Other Financing Sources, paragraph 85, which requires
disclosure of any revenues, other financing sources, or costs attributable
to the fund under accounting standards, but not legally allowable as
credits or charges to the fund.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

105 02-114	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for social
insurance meets the requirements of SFFAS No. 17, Accounting for Social
Insurance, paragraph 32(4), which requires individual program sensitivity
analyses for projection period cash flow in present value dollars and
annual cash flow in nominal dollars. The CFS includes only present value
sensitivity analyses for Social Security and Hospital Insurance. Paragraph
32(4) states that at a minimum the summary should present Social Security,
Hospital Insurance, and Supplementary Medical Insurance separately.

See status of recommendation Open. No. 02-25.

106 02-115	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for social
insurance meets the requirements of SFFAS No. 17, Accounting for Social
Insurance, paragraph 27(4)(a), which requires the individual program
sensitivity analyses for Social Security and Hospital Insurance to include
an analysis of assumptions regarding net immigration.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

107 02-118	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for nonfederal
physical property included in stewardship information meets the
requirements of SFFAS No. 8, Supplementary Stewardship Reporting,
paragraph 87, which requires disclosure of the annual investment,
including a description of federally owned physical property transferred
to state and local governments. This information should be provided for
the year ended on the balance sheet date as well as for each of the 4
preceding years. If data for additional years would provide a better
indication of investment, reporting of the additional years' data is
encouraged. Reporting should be at a meaningful category or level.

See status of recommendation Open. No. 02-25.

108 02-119	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for nonfederal
physical property included in stewardship information meets the
requirements of SFFAS No. 8, Supplementary Stewardship Reporting,
paragraph 87, which requires a description of major programs involving
federal investments in nonfederal physical property, including a
description of programs or policies under which noncash assets are
transferred to state and local governments.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

109 02-120	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for human capital
included in stewardship information meets the requirements of SFFAS No. 8,
Supplementary Stewardship Reporting, paragraph 94, which requires a
narrative description and the full cost of the investment in human capital
for the year being reported on as well as the preceding 4 years (if full
cost data are not available, outlay data can be reported).

See status of recommendation Open. No. 02-25.

110 02-121	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for human capital
included in stewardship information meets the requirements of SFFAS No. 8,
Supplementary Stewardship Reporting, paragraph 94, which requires the full
cost or outlay data for investments in human capital at a meaningful
category or level (e.g., by major program, agency, or department).

See status of recommendation Open. No. 02-25.

111 02-122 The Secretary of the Treasury  See status of              Open. 
              should                         recommendation             
              direct the Fiscal Assistant    No. 02-25.                 
              Secretary                                                 
              to ensure that the note                                   
              disclosure for                                            
              human capital included in                                 
              stewardship                                               
              information meets the                                     
              requirements of                                           
              SFFAS No. 8, Supplementary                                
              Stewardship Reporting,                                    
              paragraph 94,                                             
              which requires a narrative                                
              description                                               
              of major education and                                    
              training                                                  
              programs considered federal                               
              investments in human capital.                             

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

112 02-123	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for research and
development included in stewardship information meets the requirements of
SFFAS No. 8,

Supplementary Stewardship Reporting, paragraph 94, which requires
reporting of the annual investment made in the year ended on the balance
sheet date as well as in each of the 4 years preceding that year. (As
defined in this standard, "annual investment" includes more than the
annual expenditure reported by character class for budget execution. Full
cost shall be measured and accounted for in accordance with SFFAS No. 4,
Managerial Cost Accounting Standards for the Federal Government.) If data
for additional years would provide a better indication of investment,
reporting of the additional years' data is encouraged. In those unusual
instances when entities have no historical data, only current reporting
year data need be reported. Reporting must be at a meaningful category or
level, for example, a major program or department.

See status of recommendation Open. No. 02-25.

113 02-124 The Secretary of the Treasury  See status of              Open. 
              should                         recommendation             
              direct the Fiscal Assistant    No. 02-25.                 
              Secretary                                                 
              to ensure that the note                                   
              disclosure for                                            
              research and development                                  
              included in                                               
              stewardship information meets                             
              the                                                       
              requirements of SFFAS No. 8,                              
              Supplementary Stewardship                                 
              Reporting, paragraph 94, which                            
              requires a narrative                                      
              description of                                            
              major research and development                            
              programs.                                                 

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

114 02-125 The Secretary of the Treasury See status of               Open. 
              should                        recommendation              
              direct the Fiscal Assistant   No. 02-25.                  
              Secretary                                                 
              to ensure that the note                                   
              disclosure for                                            
              deferred maintenance meets                                
              the                                                       
              requirements of SFFAS No. 6,                              
              Accounting for Property,                                  
              Plant, and                                                
              Equipment, paragraphs 83 and                              
              84,                                                       
              which requires inclusion of                               
              the method                                                
              of measuring deferred                                     
              maintenance                                               
              for each major class of PP&E.                             

115 02-126	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for deferred
maintenance meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, paragraphs 83 and 84, which requires that
if the condition assessment survey method of measuring deferred
maintenance is used, the following should be presented for each major
class of PP&E: (1) description of requirements or standards for acceptable
operating condition, (2) any changes in the condition requirements or
standards, and (3) asset condition and a range estimate of the dollar
amount of maintenance needed to return the asset to its acceptable
operating condition.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

116 02-127	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for deferred
maintenance meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, paragraphs 83 and 84, which requires that
if the total lifecycle cost method is used, the following should be
presented for each major class of PP&E: (1) the original date of the
maintenance forecast and an explanation for any changes to the forecast;
(2) prior year balance of the cumulative deferred maintenance amount; (3)
the dollar amount of maintenance that was defined by the professionals who
designed, built, or managed the PP&E as required maintenance for the
reporting period; (4) the dollar amount of maintenance actually performed
during the period; (5) the difference between the forecast and actual
maintenance; (6) any adjustments to the scheduled amounts deemed necessary
by the managers of the PP&E and (7) the ending cumulative balance for the
reporting period for each major class of asset experiencing deferred
maintenance.

See status of recommendation Open. No. 02-25.

117 02-128	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary, to ensure that the note disclosure for deferred
maintenance meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, paragraphs 83 and 84, which requires that
if management elects to disclose critical and noncritical amounts, the
disclosure is to include management's definition of these categories.

See status of recommendation Open. No. 02-25.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

118 02-129	The Secretary of the Treasury should direct the Fiscal
Assistant Secretary to ensure that the note disclosure for stewardship
responsibilities related to the risk assumed for federal insurance and
guarantee programs meets the requirements of SFFAS No. 5, Accounting for
Liabilities of the Federal Government, paragraph 106, which requires that
when financial information pursuant to FASB standards on federal insurance
and guarantee programs conducted by government corporations is
incorporated in general purpose financial reports of a larger federal
reporting entity, the entity should report as required supplementary
information what amounts and periodic change in those amounts would be
reported under the "risk assumed" approach.

See status of recommendation Open. No. 02-25.

GAO-04-866 (results of the fiscal year 2003 audit)

119 03-1	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that if full-time equivalents (FTE) are used as part
of Treasury's methodology for allocating Office of Personnel Management
(OPM) costs, the FTEs used for the agencies listed on the Statement of Net
Cost agree with the FTEs listed in the Analytical Perspectives, Budget of
the United States Government as currently stated in Treasury's
methodology.

Closed.	Closed during the fiscal year 2004 audit. Treasury changed its
methodology and did not use the FTEs listed in the Analytical
Perspectives, Budget of the United States Government.

120 03-2 The Secretary of the         Closed.     Closed during the fiscal 
            Treasury should                                         year 2004 
            direct the Fiscal Assistant           audit. Treasury changed its 
            Secretary                            
             to document any changes to           methodology and did not use 
                        the                                               the 
               stated methodology for                      FTEs listed in the 
                     allocating                                    Analytical 
             OPM costs and the rationale          Perspectives, Budget of the 
                               for these                               United 
                      changes.                        States Government.      
121 03-3 The Secretary of the         Closed.     Closed during the fiscal 
            Treasury should                                         year 2004 
            direct the Fiscal Assistant           audit. Treasury changed its 
            Secretary                            
               to require reviews by              methodology and did not use 
                      Treasury                                            the 
            management of the accuracy                     FTEs listed in the 
            of the                                                 Analytical 
                allocated OPM costs.              Perspectives, Budget of the 
                                                                       United 
                                                      States Government.      

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

122 03-4     The Director of OMB should See status of recommendation Open. 
                                direct the                              
            Controller of OMB, in          No. 02-18.                   
            coordination                                                
            with Treasury's Fiscal                                      
            Assistant                                                   
            Secretary, to work with the                                 
            federal                                                     
            agencies so that the                                        
            differences                                                 
            between net outlays the                                     
            agencies                                                    
              report in their Statement of                              
                                 Budgetary                              
              Resources and the net outlay                              
                                   records                              
            Treasury uses to prepare the                                
            Statement of Changes in Cash                                
            Balance are reconciled.                                     

123 03-5 The Secretary of the         Treasury will wait to see the  Open. 
            Treasury should              results of                     
            direct the Fiscal Assistant  the work between Treasury,     
            Secretary                    OMB, and                       
            to determine and address the the agencies to address GAO's  
            effects                                                     
            that any of the differences  recommendation for No. 02-18.  
            between                                                     
                net outlays the agencies Pending the results of that    
                         report in their work and                       
            Statement of Budgetary       analysis, this step may not be 
            Resources                                                   
               and Treasury's net outlay                                
                             records may necessary.                     
            have on the CFS.                                            

124 03-6	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to develop a process that will allow full reporting of the
changes in cash balance of the U.S. government. Specifically, the process
should provide for reporting on the change in cash reported on the
consolidated balance sheet, which should be linked to cash balances
reported in federal agencies' audited financial statements.

Treasury disagrees with GAO. The total operating cash reported in the 2004
CFS was linked to the amounts reported in the agencies' audited financial
statements. The Statement of Changes in Cash Balance reconciles to
Operating Cash, which is in accordance with SFFAS 24. SFFAS 24, paras.
12-13, requires reconciliation to the Government Cash balance. It also
references an illustration that is not prescriptive.

Open. The Statement of Changes in Cash Balance reported only the changes
in the "operating" cash of the U.S. government of $19.8 billion rather
than the change in all cash reported on the U.S. government's Balance
Sheet of $22.6 billion, as of September 30, 2004.

125 03-7 The Secretary of the       Treasury disagrees Open. See status of 
            Treasury should                 with GAO           recommendation 
            direct the Fiscal            on this item.        No. 02-12.      
            Assistant Secretary         However, further  
            to report gross amounts       research and    
            for receipts                discussion will   
                                              take        
            and disbursements of cash   place in fiscal   
            related to                     year 2005.     
              direct loans and loan                       
                   guarantees.                            

126 03-8       The Director of OMB should OMB is participating in a  Open. 
                                  direct the multi-agency               
            Controller of OMB, in            task force that will begin 
            coordination                     to address                 
            with Treasury's Fiscal Assistant the issues related to      
                                             criminal debt.             
            Secretary, to work with Justice                             
            and                                                         
            certain other executive branch                              
            agencies to ensure that these                               
            agencies report or disclose                                 
            relevant                                                    
                criminal debt information in                            
                                  conformity                            
            with GAAP in their financial                                
                    statements and have such                            
                                 information                            
            subjected to audit.                                         

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

127 03-9 The Secretary of the Treasury  See status of recommendation Open. 
            should                                                      
            direct the Fiscal Assistant    No. 03-8.                    
            Secretary                                                   
            to include relevant criminal                                
            debt                                                        
            information in the CFS or                                   
            document                                                    
            the specific rationale for                                  
            excluding                                                   
            such information.                                           

128 03-10 The Secretary of the Treasury     Treasury plans to modify Open. 
             should                            the new                  
             direct the Fiscal Assistant       system to request        
             Secretary                         contingency loss         
             to include in the new system a    information for fiscal   
             request                           year 2005.               
             for federal agencies to provide                            
             contingency loss information to                            
             assist                                                     
             Treasury in disclosing                                     
             contingencies                                              
             in the CFS in accordance with                              
             GAAP.                                                      

129 03-11	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, in coordination with the Controller of OMB, to modify
Treasury's plans for the new closing package to (1) require federal
agencies to directly link their audited financial statement notes to the
CFS notes and (2) provide the necessary information to demonstrate that
all of the five principal consolidated financial statements are consistent
with the underlying information in federal agencies' audited financial
statements and other financial data.

See status of recommendation Open. No. 02-42.

130 03-12	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to report prior period adjustments in accordance with SFFAS No.
21 by (1) restating the prior year for corrections of material errors and
adjusting the beginning balance of cumulative results of operations and
disclosing the nature of the errors in the notes to the CFS and (2)
including corrections of immaterial errors in the current year and not
citing them as prior period adjustments on the Statement of Changes in Net
Position and not disclosing them in the notes to the CFS.

Closed.	Closed during the fiscal year 2004 audit.

                                  Appendix II
                         Status of Treasury's and OMB's
                    Progress in Addressing GAO's Prior Year
                     Recommendations for Preparing the CFS

                           Status of recommendations

131 03-13 The Secretary of the Treasury should   Closed. Closed during the 
                                                             fiscal year 2004 
             direct the Fiscal Assistant Secretary               audit.       
             to include in Treasury's new closing           
               package a process that will allow            
             federal agencies to clearly                    
             distinguish                                    
             between prior period adjustments and           
             changes in accounting principles in            
                 accordance with SFFAS No. 21.              

132 03-14	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, to ensure that the note disclosure for federal employees and
veterans benefits payable meets the requirements of SFFAS No. 5,
Accounting for Liabilities of the Federal Government, paragraph 65, which
requires that the actuarial assumptions be the basis of the actual
experience of the covered group, to the extent that credible experience
data are available, but should emphasize expected long-term future trends
rather than give undue weight to recent experience.

Closed.	Closed during the fiscal year 2004 audit.

133 03-15	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary, to ensure that the note disclosure for federal employees and
veterans benefits payable meets the requirements of SFFAS No. 5,
Accounting for Liabilities of the Federal Government, paragraph 83, which
requires the reporting entity to disclose the assumptions used for
veterans compensation and burial benefits.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

134 03-16	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for federal employees and
veterans benefits payable meets the requirements of SFFAS No. 5,
Accounting for Liabilities of the Federal Government, paragraph 72, which
requires the reporting entity to disclose prior service costs from plan
amendments as a separate component.

See status of recommendation Open. No. 02-25.

135 03-17	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for federal employees and
veterans benefits payable meets the requirements of SFFAS No. 5,
Accounting for Liabilities of the Federal Government, paragraph 88, which
requires the reporting entity to disclose gains or losses due to a change
in the medical inflation rate assumption for health benefits as a separate
component.

See status of recommendation Open. No. 02-25.

136 03-18 The Secretary of the Treasury  See status of               Open. 
             should                         recommendation              
             direct the Fiscal Assistant    No. 02-25.                  
             Secretary                                                  
             to ensure that the note                                    
             disclosure for                                             
             environmental and disposal                                 
             liabilities                                                
             meets the requirements of                                  
             SFFAS                                                      
             No. 6, Accounting for                                      
             Property, Plant,                                           
             and Equipment, which requires                              
             the                                                        
             reporting entity to disclose                               
             the method                                                 
             for assigning estimated total                              
             cleanup                                                    
             costs to current operating                                 
             periods.                                                   

137 03-19	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for environmental and
disposal liabilities meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, which requires the reporting entity to
disclose, for cleanup costs associated with general property, plant, and
equipment, the unrecognized portion of estimated total cleanup costs be
disclosed.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

138 03-20	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the note disclosure for environmental and
disposal liabilities meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, which requires the reporting entity to
disclose the nature of estimates and information regarding possible
changes to the estimates resulting from inflation, deflation, technology,
or applicable laws and regulations.

See status of recommendation Open. No. 02-25.

139 03-21 The Secretary of the Treasury  See status of               Open. 
             should                         recommendation              
             direct the Fiscal Assistant    No. 02-25.                  
             Secretary                                                  
             to consider whether the reader                             
             would                                                      
             be interested in understanding                             
             why                                                        
             the environmental and disposal                             
             liabilities amount                                         
             significantly changed                                      
             during the year and include                                
             the                                                        
             explanation for the change in                              
             the note                                                   
             disclosure.                                                

140 03-22	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the information in stewardship information for
research and development meets the requirements of SFFAS No. 8,
Supplementary Stewardship Reporting, paragraph 99, which requires the
reporting entity to include a narrative discussion of the major results
achieved by the program along the lines of basic research, applied
research, and development.

See status of recommendation Open. No. 02-25.

Appendix II
Status of Treasury's and OMB's
Progress in Addressing GAO's Prior Year
Recommendations for Preparing the CFS

                           Status of recommendations

141 03-23	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the information in stewardship information for
research and development meets the requirements of SFFAS No. 8,
Supplementary Stewardship Reporting, paragraph 99, which requires the
reporting entity to include a narrative description of the major results
achieved through the investments in basic research, applied research, and
development.

See status of recommendation Open. No. 02-25.

142 03-24	The Secretary of the Treasury should direct the Fiscal Assistant
Secretary to ensure that the required supplemental information for
deferred maintenance meets the requirements of SFFAS No. 6, Accounting for
Property, Plant, and Equipment, paragraph 83, which requires the reporting
entity to disclose the identification of each major class of asset (i.e.,
building and structures, furniture and fixtures, equipment, vehicles, and
land) for which maintenance has been deferred.

See status of recommendation Open. No. 02-25.

                                  Source: GAO.

Appendix III

Comments from the Department of the Treasury

Appendix III
Comments from the Department of the
Treasury

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