Financial Audit: Restatement to the General Services		 
Administration's Fiscal Year 2003 Financial Statements		 
(06-DEC-05, GAO-06-70R).					 
                                                                 
The Secretary of the Treasury, in coordination with the Director 
of the Office of Management and Budget (OMB), is required to	 
annually prepare and submit audited financial statements of the  
U.S. government to the President and Congress. We are required to
audit these consolidated financial statements (CFS) and report on
the results of our work. An issue meriting concern and close	 
scrutiny that emerged during our fiscal year 2004 CFS audit was  
the growing number of Chief Financial Officers (CFO) Act agencies
that restated certain of their financial statements for fiscal	 
year 2003 to correct errors. Errors in financial statements can  
result from mathematical mistakes, mistakes in the application of
accounting principles, or oversight or misuse of facts that	 
existed at the time the financial statements were prepared.	 
Frequent restatements to correct errors can undermine public	 
trust and confidence in both the entity and all responsible	 
parties. Further, when restatements do occur, it is important	 
that financial statements clearly communicate, and readers of the
restated financial statements understand, that the financial	 
statements originally issued by management in the previous year  
and the opinion thereon should no longer be relied on and instead
the restated financial statements and related auditor's opinion  
should be used. Because of the varying nature and circumstances  
surrounding the restatements, we are issuing a number of separate
reports on the matter. This report communicates our observations 
regarding GSA's fiscal year 2003 restatement. Going forward, we  
hope that the lessons learned from the fiscal year 2003 	 
restatement, together with our recommendations, will help GSA and
its auditor avoid the need for restatements to GSA's future	 
financial statements. We reviewed four key areas with respect to 
the restatement of GSA's fiscal year 2003 financial statements:  
(1) the nature and cause of the errors that necessitated the	 
restatement, including planned corrective actions by the agency  
and its auditors; (2) the timing of communicating the material	 
misstatement to users of the financial statements; (3) the extent
of transparency exhibited in disclosing the nature and impact of 
the material misstatement in the financial statements and the	 
reissued auditor's report; and (4) audit issues that contributed 
to the failure to detect the errors that necessitated the	 
restatement during the audit of the agency's fiscal year 2003	 
financial statements.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-70R 					        
    ACCNO:   A42637						        
  TITLE:     Financial Audit: Restatement to the General Services     
Administration's Fiscal Year 2003 Financial Statements		 
     DATE:   12/06/2005 
  SUBJECT:   Accounting errors					 
	     Accounting standards				 
	     Auditing procedures				 
	     Auditing standards 				 
	     Financial statement audits 			 
	     Financial statements				 
	     Internal controls					 
	     Reporting requirements				 
	     Transparency					 

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GAO-06-70R

December 6, 2005

Ms. Kathleen M. Turco Chief Financial Officer General Services
Administration

The Honorable Brian D. Miller Inspector General

General Services Administration

Subject: Financial Audit: Restatement to the General Services
Administration's Fiscal Year 2003 Financial Statements

As you know, the Secretary of the Treasury, in coordination with the
Director of the Office of Management and Budget (OMB), is required to
annually prepare and submit audited financial statements of the U.S.
government to the President and Congress. We are required to audit these
consolidated financial statements (CFS) and report on the results of our
work.1 An issue meriting concern and close scrutiny that emerged during
our fiscal year 2004 CFS audit was the growing number of Chief Financial
Officers (CFO) Act agencies that restated2 certain of their financial
statements for fiscal year 2003 to correct errors.3 Errors in financial
statements can result from mathematical mistakes, mistakes in the
application of accounting principles, or oversight or misuse of facts that
existed at the time the financial statements were prepared. Frequent
restatements to correct errors can undermine public trust and confidence
in both the entity and all responsible parties. Further, when restatements
do occur, it is important that financial statements clearly communicate,
and readers of the restated financial statements understand, that the
financial statements originally issued by management in the previous year
and the opinion thereon should

1The Government Management Reform Act of 1994 has required such reporting,
covering the executive branch of government, beginning with financial
statements prepared for fiscal year 1997. 31 U.S.C. S: 331 (e). The
federal government has elected to include certain financial information on
the legislative and judicial branches in the CFS as well.

2A financial statement restatement occurs when an entity either
voluntarily or prompted by its auditors or regulators revises public
financial information that has previously been reported.

3According to Federal Accounting Standards Advisory Board, Statement of
Federal Financial Accounting Standards (SFFAS) No. 21, Reporting
Corrections of Errors and Changes in Accounting Principles, prior period
financial statements presented should be restated only to correct errors
that caused such statements to be materially misstated.

no longer be relied on and instead the restated financial statements and
related auditor's opinion should be used.

Eleven of the 23 CFO Act agencies4 restated certain of their financial
statements for fiscal year 2003. Five CFO Act agencies had restatements in
fiscal year 2003 covering their fiscal year 2002 financial statements.
Three CFO Act agencies had restatements covering both years. We noted that
the extent of the restatements to CFO Act agencies' fiscal year 2003
financial statements varied from agency to agency, ranging from correcting
two line items on one agency's balance sheet to correcting numerous line
items on several of another agency's financial statements. In some cases,
the net operating results of the agency were affected by the restatement.
The amounts of the agencies' restatements ranged from several million
dollars to more than $91 billion.

Nine of the 11 agencies that had restatements for fiscal year 2003
received unqualified opinions on their originally issued fiscal year 2003
financial statements. The auditors for 6 of these 9 agencies issued
unqualified opinions on the restated financial statements, replacing the
previous unqualified opinions on the respective agencies' original fiscal
year 2003 financial statements. The auditors for 2 of these 9 withdrew
their unqualified opinions on the fiscal year 2003 financial statements
and issued other than unqualified opinions on the respective agencies'
restated fiscal year 2003 financial statements because they could not
determine whether there were any additional misstatements and the effect
of any such misstatements on the restated fiscal year 2003 financial
statements. For the remaining agency, the principal auditor of the
agency's fiscal year 2004 financial statements was not the principal
auditor of the agency's fiscal year 2003 financial statements, and an
audit opinion on the agency's restated fiscal year 2003 financial
statements was not issued.

Our review focused on the 9 agencies with restatements for fiscal year
2003 that received unqualified opinions on their originally issued fiscal
year 2003 financial statements.5 These were the Department of Agriculture,
Department of State, Department of Justice, Department of Transportation,
Department of Health and Human Services, General Services Administration
(GSA), National Science Foundation, Nuclear Regulatory Commission, and
Office of Personnel Management.

Because of the varying nature and circumstances surrounding the
restatements, we are issuing a number of separate reports on the matter.
This report communicates our observations regarding GSA's fiscal year 2003
restatement. Going forward, we hope that the lessons learned from the
fiscal year 2003 restatement, together with our recommendations, will help
GSA and its auditor avoid the need for restatements to GSA's future
financial statements.

4The Federal Emergency Management Agency (FEMA) was transferred to the
Department of Homeland Security (DHS) effective March 1, 2003. With this
transfer, FEMA was no longer required to prepare and have audited
stand-alone financial statements under the CFO Act, leaving 23 CFO Act
agencies for the remainder of fiscal year 2003 and for fiscal year 2004.
The DHS Financial Accountability Act, Pub. L. No. 108-330, 118 Stat. 1275
(Oct. 16, 2004), added DHS to the list of CFO Act agencies, increasing the
number of CFO Act agencies again to 24 beginning in fiscal year 2005.

5The 2 agencies that had restatements for fiscal year 2003 but did not
receive unqualified opinions on their originally issued fiscal year 2003
financial statements were the Department of Defense and the Small Business
Administration.

We reviewed four key areas with respect to the restatement of GSA's fiscal
year 2003 financial statements: (1) the nature and cause of the errors
that necessitated the restatement, including planned corrective actions by
the agency and its auditors; (2) the timing of communicating the material
misstatement to users of the financial statements; (3) the extent of
transparency6 exhibited in disclosing the nature and impact of the
material misstatement in the financial statements and the reissued
auditor's report; and (4) audit issues that contributed to the failure to
detect the errors that necessitated the restatement during the audit of
the agency's fiscal year 2003 financial statements.

Results in Brief

Improperly transferring costs related to one major construction project
out of the Construction in Process (CIP)7 account and into the Buildings
account led to the material misstatement that necessitated the restatement
of two separate and distinct line items on GSA's originally issued fiscal
year 2003 Balance Sheet. Specifically, at fiscal year 2003 year end, GSA
recorded an adjusting journal entry to transfer about $952 million of
construction costs from the CIP account to the Buildings account. This
amount was derived based on a statistical sample of construction projects
included in GSA's unadjusted year-end balance for the CIP account. The
largest project included in GSA's statistical sample was a multiphase
project totaling about $68.6 million, which was incorrectly classified as
substantially complete8 at that time. This incorrect classification, when
projected to the population of CIP projects, was the basis for about $921
million of the $952 million, or over 96 percent, of the estimated costs
transferred at year end.

GSA's auditor did not detect the error because its fiscal year 2003 audit
tests were not adequately designed to test the validity of GSA's transfers
of construction costs between the two accounts. Although the journal entry
used to record the transfer between the accounts involved a material
amount and GSA's contracted independent public accountant (IPA) had
reported a reportable condition relating to CIP transfers in its previous
two years audit reports, in our view, the IPA did not adequately
understand the significant components underlying this journal entry. As a
result, the IPA randomly selected 10 projects from GSA's statistical
sample of 99 projects and did not review the above noted project that GSA
had incorrectly classified. Further, in our view, the title of GSA's note
disclosure of the restatement could be misinterpreted.

6Transparency is the full, accurate, and timely disclosure of information.

7The United States General Ledger uses the term Construction in Progress,
but GSA presents this account as Construction in Process in the fiscal
year 2003 financial statements. We will use the term Construction in
Process (CIP) to refer to the account.

8According to the IPA's Property Cycle memorandum, GSA defines substantial
completion as the date when GSA can use the constructed item for its
intended use. Substantial completion is not equivalent to the completion
date for the contract. Substantial completion is also the date for the
transfer of the project from the work in process account to the Buildings
account.

We are recommending that GSA's CFO ensures that GSA fully and effectively
implements control procedures to properly transfer costs from the CIP
account to the Buildings account. We are also making a recommendation to
GSA's Inspector General to work with the IPA so that audit procedures to
sufficiently test for any similar errors in the transfer of amounts from
the CIP account to the Buildings account in the future are implemented.

GSA, along with its Inspector General concurred with our recommendations
for ensuring reliable balances in the CIP and Buildings accounts. In
separate responses on a draft of this report, they described the
accounting and auditing procedures planned to avoid similar restatements
of this nature in the future.

Background

In conducting the fiscal year 2004 audit of the CFS, we reviewed the 23
CFO Act agencies' performance and accountability reports for possible
restatements and identified 11 agencies that had restated certain of their
audited fiscal year 2003 financial statements.

The primary intended users of federal agencies' financial reports are
citizens, Congress, federal executives, and federal program managers.9
Each of these groups may use federal agencies' financial statements to
satisfy their specific needs. Citizens are interested in many aspects of
the federal government, particularly federal programs that affect their
financial well-being. Congress is interested in monitoring and assessing
the efficiency and effectiveness of federal programs. Federal executives,
such as central agency officials at OMB and the Department of the Treasury
(Treasury), are interested in federal financial statements to assist the
President of the United States. OMB assists the President in overseeing
the preparation of the federal budget by formulating the President's
spending plans, evaluating the effectiveness of agency programs, assessing
competing funding demands among agencies, and setting funding priorities.
Treasury assists the President in managing the finances of the federal
government and prepares the CFS, which is based on audited financial
statements prepared by federal agencies. GAO audits the CFS and reports on
the results of its audit. Finally, federal program managers use agency
financial statements as tools for managing their operations within the
limits of the spending authority granted by Congress.

The primary accounting and auditing standards that apply to restatement
disclosures by federal entities are the Federal Accounting Standards
Advisory Board's Statement of Federal Financial Accounting Standards
(SFFAS) No. 21, Reporting Corrections of Errors and Changes in Accounting
Principles, and the American Institute of Certified Public Accountants
(AICPA) Codification of Auditing Standards, AU section 561, Subsequent
Discovery of Facts Existing at the Date of the Auditor's Report.10

9Federal Accounting Standards Advisory Board, Statement of Federal
Financial Accounting Concepts No. 1, Objectives of Federal Financial
Reporting.

Objective, Scope, and Methodology

The objective of our review of the restatement of GSA's fiscal year 2003
financial statements was to determine the nature and cause of the errors,
the transparency and timing of communicating the material misstatements,
any audit issues relating to such misstatements, and any actions being
taken to help preclude similar errors from occurring in the future.

We reviewed the nature and causes of the restatement, and we also examined
corrective action plans to be implemented by GSA to help preclude similar
errors from occurring in the future. We interviewed the preparers and
auditors of GSA's fiscal year 2003 financial statements, including staff
from the agency's Office of Inspector General (OIG), and we obtained and
reviewed relevant audit documentation. Our work was not designed to and we
did not test the accuracy or appropriateness of the restatement.

In our review, we considered certain accounting and auditing standards,
including SFFAS No. 21; the Financial Accounting Standards Board's
Statement of Financial Accounting Standards No. 16, Prior Period
Adjustments; and the AICPA Codification of Auditing Standards, AU section
420, Consistency of Application of Generally Accepted Accounting
Principles, AU section 508, Reports on Audited Financial Statements, and
AU section 561.

We performed our review of the restatement of GSA's fiscal year 2003
financial statements from December 2004 to October 2005 in accordance with
U.S. generally accepted government auditing standards.

We requested comments on the draft of this report from GSA's CFO and
Inspector General or their designees. Written comments from GSA's Acting
Administrator and Inspector General are reprinted in enclosures I and II,
respectively, and are also discussed in the Agency Comments section.

Issues Related to Restatement of GSA's Fiscal Year 2003 Balance Sheet

With respect to the restatement of GSA's fiscal year 2003 Balance Sheet,
we identified the following three areas that need improvement: (1)
identification of substantially complete CIP transfers, (2) design of
audit procedures relating to adjusting journal entries used to transfer
amounts from the CIP account, and (3) the title of the note disclosure of
the restatement. These issues are discussed in detail below.

10Generally accepted government auditing standards incorporate AICPA
reporting standards and Statements on Auditing Standards unless the
Comptroller General of the United States excludes them by formal
announcement.

Adjustment to CIP and Buildings Accounts Were Erroneous

GSA's Balance Sheet for fiscal year 2003 was restated because of an error
in the adjusting journal entry that was used to transfer approximately
$952 million of estimated costs from the CIP account to the Buildings
account. The error caused the Buildings line item on the Balance Sheet to
be materially overstated by approximately $921 million and the CIP line
item on the Balance Sheet to be materially understated by this same
amount.

The CIP general ledger account includes construction of, and major
improvements and renovation projects to, buildings that GSA owns and
leases to other federal entities. Upon substantial completion, certain
costs are to be transferred to the appropriate Property and Equipment
(P&E) asset account. The transfer from the CIP account to the appropriate
P&E account is necessary for proper classification of assets in the
Balance Sheet as well as accurate and complete reporting of depreciation
expenses. Depreciation is not calculated and recorded until the asset is
transferred from CIP to the appropriate asset account.

When a new CIP project is established, regional personnel are expected to
enter all necessary information, including the expected date of completion
into the Inventory Reporting Information System (IRIS) that GSA management
uses to monitor the status of construction projects. Construction costs
are accumulated in the CIP account. Once a project is substantially
complete, the project manager is supposed to enter the date of substantial
completion into IRIS so that the CIP account project costs will be
automatically transferred into the Real Property Accounting Depreciation
System (RPADS). Also, building projects that meet certain capitalization
criteria and are determined to have been substantially completed during
the reporting period should be transferred to the Buildings account from
the CIP account.

Transfers of the costs of substantially completed projects from the CIP to
the appropriate P&E account are necessary for proper classification of the
related assets in the Balance Sheet. For fiscal year 2003, GSA's net
Buildings account and CIP account totaled about 52 percent of its total
assets. However, according to the IPA's fiscal year 2004 Report on
Internal Control, since fiscal year 2001, GSA has experienced problems
related to cost transfers from CIP to the appropriate P&E account.
Specifically, the IPA's report noted that GSA's Public Buildings Service
(PBS) controls over transferring substantially complete CIP projects
continue to need improvement.

GSA has been aware that weaknesses in these processes can lead to the
failure to recognize the completion of construction projects on a timely
basis. Among the causes of the underlying weaknesses previously reported
by GSA's auditor are regional personnel not entering completion dates in
IRIS, and manual procedures performed by central staff not addressing all
CIP issues. In order to mitigate these control weaknesses, each quarter
GSA's PBS uses a random statistical sample to assess the accuracy of data
in its RPADS and makes an adjusting journal entry to correct for any
errors for reporting purposes.

Based on PBS's review of a statistical sample of projects still classified
in IRIS as CIP at the end of fiscal year 2003, GSA recorded an adjusting
journal entry to transfer about $952 million of estimated costs from the
CIP account to the Buildings account. In September 2004, during GSA's OIG
review of GSA's quarterly financial statements, the OIG discovered an
error in the agency's classification of the largest project included in
GSA's end of fiscal year 2003 statistical sample. Specifically, the OIG
found that PBS incorrectly classified a $68.6 million multiphase project
from the fiscal year 2003 CIP sample as substantially complete when it
should have remained in CIP. PBS identified the multiphase project as
substantially complete without obtaining written documentation from the
region responsible for the project to support such a determination. This
incorrect classification, when projected to the population of CIP
projects, was the basis for about $921 million of the approximately $952
million of the estimated costs that were transferred. As a result, GSA's
adjusting journal entry to transfer approximately $952 million in
estimated costs from the CIP account to the Buildings account was
overstated by about $921 million. GSA's OIG communicated the error to GSA
management and to the IPA in September 2004, which was appropriate. After
researching the issue, GSA management concurred that the error warranted
an adjustment to restate the CIP and Buildings line items on the fiscal
year 2003 Balance Sheet.

To reduce the risk of similar errors in the future, GSA officials told us
that GSA has refined its methodology for determining the CIP transfer
amounts. Starting with fiscal year 2005, GSA will semi-annually review all
of the CIP projects over $7 million and statistically sample the remaining
lower cost CIP projects to develop an adjusting journal entry, if
necessary. In addition, according to GSA's Corrective Action Plan, GSA
intends to improve its controls over transferring substantially complete
CIP projects by enforcing its control procedures at the project level to
ensure that all substantially complete and only substantially complete CIP
projects are transferred out of the CIP account. GSA's plan calls for GSA
regions to make entries into a weekly nationwide CIP Progress Report to
certain GSA officials regarding the number of projects: (1) with no
substantial completion date, (2) with substantial completion dates in the
past, and (3) marked to be completed in the current month. In addition,
according to GSA's Plan, PBS intends to work with regions to develop
regional action plans that enforce entering timely substantial completion
dates at the project level.

Auditor's Procedures Were Not Adequately Designed to Detect Error in the
Transfer of CIP Costs

The above-noted error was not discovered during the audit of GSA's fiscal
year 2003 financial statements because the fiscal year 2003 audit
procedures performed by GSA's IPA were not adequately designed to detect
the error. The journal entry used to record the transfer between the
accounts involved a material amount and GSA's IPA had reported a
reportable condition relating to CIP transfers in its previous two years
audit reports. In addition, as noted above, over 96 percent of the
estimated costs that were transferred resulted from the incorrectly
classified multiphase project. Nevertheless, the IPA randomly selected 10
projects from GSA's statistical sample of 99 projects and did not review
the largest cost project in the sample, which is the above noted project
that GSA had incorrectly classified.

The Financial Audit Manual (FAM)11 states that during the audit planning
process, the auditor should identify conditions that significantly
increase inherent, fraud, and control risk. Among other things, the
auditor should perform procedures to identify account balances and
transactions that might signal inherent risk. According to FAM 260.40, the
auditor should obtain an understanding of the financial reporting process
and the controls over journal entries and other adjustments; identify and
select journal entries and other adjustments for testing; determine the
nature, timing, and extent of the testing; and inquire of individuals
involved in the financial reporting process about inappropriate or unusual
activity related to the processing of journal entries and adjustments. In
our view, if the IPA had had a better understanding of the significant
components of the calculations used to determine the material adjusting
journal entry that transferred construction costs from the CIP account to
the Buildings account and had then designed and performed sufficient audit
procedures over such components, the error that necessitated the
restatement might have been detected.

According to GSA's IPA, future audits will include testing more projects
from GSA's sample. Specifically, the IPA intends to increase the sample
size from 10 to about 45. Given the known risks in this area, it will be
important for the IPA to perform adequate audit procedures over any
significant adjusting journal entries made by GSA to transfer CIP costs.

The Title of GSA's Note Disclosure of the Restatement Could Be
Misinterpreted

The notes to GSA's comparative fiscal years 2004 and 2003 financial
statements included a note disclosure titled "Prior Period
Reclassification." In our view, this title could be misinterpreted, since
the note disclosure discussed the adjustment to correct the $921 million
material misstatement and the adjustment represented a restatement as
defined by SFFAS No. 21 rather than a prior period reclassification.

Conclusions

The restatement was caused by an error that GSA's OIG identified. GSA
corrected the error and issued restated financial statements. Going
forward, the key will be for GSA to ensure that the planned corrective
actions established to help prevent future errors in the transfer of CIP
costs are fully and effectively implemented. In addition, it will be
important that GSA's OIG work with GSA's IPA so that audit procedures to
detect any similar errors in the future are fully and effectively
implemented.

11GAO/President's Council on Integrity and Efficiency, Financial Audit
Manual, GAO-01-765G (Washington, D.C.: July 2001), updated by GAO-04-1015G
and GAO-04-924G (July 2004).

Recommendations for Executive Action

We recommend that GSA's Chief Financial Officer ensure that GSA fully and
effectively implements control procedures to properly transfer costs from
the CIP account to the Buildings account.

We recommend that GSA's Inspector General, work with GSA's IPA so that
audit procedures to sufficiently test adjusting journal entries related to
the transfer of amounts from the CIP account to the Buildings account are
fully and effectively implemented.

Agency Comments

In commenting on a draft of this report, GSA's Acting Administrator stated
that GSA concurs with our recommendation to implement control procedures
to properly transfer costs from the CIP account to the Buildings account
and has made changes in the statistical sample process as we acknowledged
in our report. He also stated that GSA developed a weekly report that is
sent to the regional offices to highlight the CIP projects where the
estimated substantial completion date is overdue, missing, or scheduled to
occur within 30 days to assist in ensuring the CIP projects are accurately
capitalized and depreciated in a timely fashion. GSA's Inspector General
concurred with our recommendation and stated that his office will continue
to work with the IPA regarding auditing the transfer of CIP to the
Buildings account and that since fiscal year 2003, the IPA's testing in
this area has expanded to reduce the likelihood that a similar error would
occur in the future. He also stated that his office will continue to
monitor the IPA's efforts to plan and perform its tests of the adjusting
journal entries related to the transfer of amounts from the CIP account to
the Buildings account.

                                   - - - - -

Within 60 days of the date of this report, we would appreciate receiving a
written statement on actions taken to address these recommendations.

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
Controller of OMB. This report is also available at no charge on GAO's Web
site at www.gao.gov.

We appreciate the courtesy and cooperation extended to us by your staff
throughout our work. We look forward to continuing to work with your
offices to help improve financial management in the federal government. If
you have any questions about the contents of this report, please contact
me at (202) 512-3406 or [email protected].

Gary T. Engel

Director

Financial Management and Assurance

Enclosure I: Comments from the Acting Administrator, General Services
Administration

Enclosure I

Enclosure II: Comments from the Inspector General, General Services
Administration

(198396)

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