Financial Audit: Restated Financial Statements: Agencies'	 
Management and Auditor Disclosures of Causes and Effects and	 
Timely Communication to Users (05-OCT-06, GAO-07-91).		 
                                                                 
GAO continues to have concerns about restatements to federal	 
agencies' previously issued financial statements. During fiscal  
year 2005, at least 7 of the 24 Chief Financial Officers (CFO)	 
Act agencies restated certain of their fiscal year 2004 financial
statements to correct misstatements. To study this trend, GAO	 
reviewed the nature and causes of the restatements made by	 
certain CFO Act agencies in fiscal year 2004 to their fiscal year
2003 financial statements. Eleven CFO Act agencies had		 
restatements for fiscal year 2003. Nine of those 11 received	 
unqualified opinions on their originally issued fiscal year 2003 
financial statements. GAO's view is that users of federal	 
agencies' financial statements and the related audit reports need
to be provided at least a basic understanding of why a		 
restatement was necessary and its effect on the agencies'	 
previously issued financial statements and related audit reports.
This report communicates GAO's observations on the transparency  
and timeliness of the 9 federal agencies' and their auditors'	 
restatement disclosures.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-91						        
    ACCNO:   A61866						        
  TITLE:     Financial Audit: Restated Financial Statements: Agencies'
Management and Auditor Disclosures of Causes and Effects and	 
Timely Communication to Users					 
     DATE:   10/05/2006 
  SUBJECT:   Accounting errors					 
	     Accounting standards				 
	     Audit reports					 
	     Financial analysis 				 
	     Financial disclosure				 
	     Financial records					 
	     Financial statement audits 			 
	     Financial statements				 
	     Timeliness 					 
	     Transparency					 

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GAO-07-91

     

     * Results in Brief
     * Background
     * Objectives, Scope, and Methodology
     * Insufficient and Inconsistent Disclosure of Financial Statem
          * Issues Regarding Agencies' Restatement Disclosures
               * Labeling of Restated Financial Statements
               * Restatements to Certain Agencies' Statement of Changes in Ne
               * Agencies' Restatement Footnotes
               * Disclosure of Restatements in Agencies' Management's Discuss
          * Issues Regarding Auditors' Restatement Disclosures
     * Timely Communication of Material Misstatements to Users of P
          * Issues Regarding Timeliness of Management's Communication of
          * Issues Regarding Timeliness of Certain Auditors' Restatement
     * Conclusions
     * Recommendations for Executive Action
     * Agency Comments and Our Evaluation
     * Recommendations Regarding OMB Circular No. A-136
     * Recommendations Regarding OMB Bulletin No. 06-03
     * GAO Contact
     * Acknowledgments
     * GAO's Mission
     * Obtaining Copies of GAO Reports and Testimony
          * Order by Mail or Phone
     * To Report Fraud, Waste, and Abuse in Federal Programs
     * Congressional Relations
     * Public Affairs

Report to theDirector, Office of Management and Budget

United States Government Accountability Office

GAO

October 2006

FINANCIAL AUDIT

Restated Financial Statements: Agencies' Management and Auditor
Disclosures of Causes and Effects and Timely Communication to Users

GAO-07-91

Contents

Letter 1

Results in Brief 4
Background 8
Objectives, Scope, and Methodology 9
Insufficient and Inconsistent Disclosure of Financial Statement
Restatements by Certain Federal Agencies and Their Auditors 11
Timely Communication of Material Misstatements to Users of Previously
Issued Financial Statements 18
Conclusions 24
Recommendations for Executive Action 24
Agency Comments and Our Evaluation 25
Appendix I Recommendations to OMB 27
Recommendations Regarding OMB Circular No. A-136 27
Recommendations Regarding OMB Bulletin No. 06-03 31
Appendix II GAO Contact and Staff Acknowledgments 37
Related GAO Products 38

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separately.

United States Government Accountability Office

Washington, DC 20548

                                                          Comptroller General

                                                         of the United States

October 5, 2006

The Honorable Rob Portman Director Office of Management and Budget

Dear Mr. Portman:

We continue to have concerns about restatements to federal agencies'
previously issued financial statements. During fiscal year 2005, at least
7 of the 24 Chief Financial Officers (CFO) Act agencies restated certain
of their fiscal year 2004 financial statements to correct misstatements.
To study this trend, we reviewed the nature and causes of the restatements
made by certain CFO Act agencies in fiscal year 2004 to their fiscal year
2003 financial statements.1 Our audit of the consolidated financial
statements of the U.S. government (CFS) for fiscal years 2004 and 2003
showed that 11 CFO Act agencies had restated one or more of their fiscal
year 2003 financial statements to correct misstatements.2 Nine of the 11
agencies had received an unqualified audit opinion on their originally
issued financial statements. Because of the significant increase in the
number of restatements identified during our fiscal year 2004 audit, we
initiated a review of the nature and causes of these 9 federal agencies'
restatements.

Accounting principles attribute errors in recognition, measurement,
presentation, or disclosure in previously issued financial statements to
(1) mathematical mistakes, (2) mistakes in the application of generally
accepted accounting principles (GAAP), or (3) oversight or misuse of facts
when the financial statements were prepared. Restatements occur when an
entity, either voluntarily or prompted by its auditors or regulators,
revises previously issued financial statements. Accounting standards state
that financial statements should only be restated for the correction of
errors that would have caused any statements to be materially misstated.
Therefore, restatements should not occur if misstatements in previously
issued financial statements are not material. Such standards further state
that the restated financial statements should disclose the nature of the
misstatement and effect of its correction on relevant balances. The Office
of Management and Budget (OMB) has issued guidance to federal agencies'
management regarding disclosure of restatements to previously issued
financial statements. Generally accepted government auditing standards
(GAGAS)3 discuss the auditors' responsibilities when they become aware of
information affecting previously issued financial statements, including
corrections of material misstatements. GAGAS stress the importance of
timely communication of restatements to users relying or likely to rely on
the previously issued financial statements. The proposed 2006 revision of
GAGAS includes an additional section on reporting on restatement of
previously issued financial statements. In addition, on August 23, 2006,
OMB issued Bulletin No. 06-03,4 which also provides some information
regarding reporting on restatements.

1This report focuses only on those corrections of errors that resulted in
restatements to agencies' fiscal year 2003 financial statements. Changes
to prior period financial statements may also occur as a result of changes
in accounting principles, where specifically required by Federal
Accounting Standards Advisory Board (FASAB) standards, and changes in
reporting entity.

2According to American Institute of Certified Public Accountants,
Codification of Auditing Standards, AU section 110, Responsibilities and
Functions of the Independent Auditor (1972), misstatements can be caused
by error (unintentional) or fraud (intentional). The meaning of the term
"error," as used in accounting principles, is consistent with the meaning
of the term "misstatement."

We believe that federal agencies' financial statements and the related
audit reports should provide users with at least a basic understanding of
why a restatement was necessary and the effect of the restatement on the
agencies' previously issued financial statements and related audit
reports. In keeping with full transparency,5 when restatements occur,
restated financial statements should clearly communicate that the
financial statements previously issued by management and the opinion
thereon should no longer be relied on and instead the restated financial
statements and the related auditor's opinion should be used. In addition,
timely communication of restatements is critical to prevent users of
federal agencies' financial statements and the related audit reports from
inadvertently relying on inaccurate information.

3GAGAS, promulgated by the Comptroller General of the United States, are
to be followed by federal auditors and audit organizations and by other
auditors auditing federal organizations, programs, or activities when
required by law, contract, or policy. These standards pertain to auditors'
professional qualifications, the quality of audit effort, and the
characteristics of professional and meaningful audit reports. GAGAS
incorporate American Institute of Certified Public Accountants' field work
and reporting standards and the related Statements on Auditing Standards
for financial audits unless the Comptroller General of the United States
excludes them by formal announcement.

4OMB Bulletin No. 06-03, Audit Requirements for Federal Financial
Statements, August 23, 2006, supersedes OMB Bulletin No. 01-02, Audit
Requirements for Federal Financial Statements, October 16, 2000.

5Transparency is the full, accurate, and timely disclosure of information.

Restatements are not unique to the federal government. Over the past
several years, we have seen a number of corporate scandals as well as
restatements by public companies.6 In response, the Congress enacted the
Sarbanes-Oxley Act7 in 2002 to strengthen corporate governance and improve
transparency and accountability to help ensure the accuracy and integrity
of the financial reporting system in the private sector to protect
investors. In addition, in May 2005, the Financial Accounting Standards
Board's (FASB) Statement of Financial Accounting Standards (FAS) No. 154,
Accounting Changes and Error Corrections,8 was issued. FAS No. 154
requires nongovernmental entities to disclose that their previously issued
financial statements have been restated, a description of the nature of
the error, the effect of the correction on each financial statement line
item, and the cumulative effect of change in the statement of financial
position. Further, the Securities and Exchange Commission (SEC) now
requires companies to disclose restatements in the Form 8-K.9
Specifically, under the Form 8-K requirements, if a company is advised by
its auditor that disclosure should be made to prevent future reliance on a
previously issued audit report or completed interim review related to
previously issued financial statements, the company should disclose (1)
the date on which it was so advised or notified, (2) the financial
statements that should no longer be relied upon, (3) a brief description
of the information provided by the auditor, and (4) a statement of whether
the audit committee or the board of directors discussed with the auditor
the matters disclosed in the filing.

America's taxpayers deserve no less in terms of transparency,
accountability, disclosure, and notification from federal agencies.
Between September 2005 and January 2006, we issued reports covering five
of the nine CFO Act agencies that had received unqualified audit opinions
on, but subsequently restated, their originally issued fiscal year 2003
financial statements.10 We reported that these restatements generally
resulted from (1) lack of effective internal controls over the processing
and reporting of certain transactions and (2) failure of the auditors to
design and/or perform adequate audit procedures to detect such
misstatements. During our fieldwork, December 2004 through October 2005,
our review of these nine agencies also focused on the following two key
areas: (1) the extent of transparency exhibited in disclosing the nature
and cause of the misstatement and its impact on the financial statements
and the reissued or updated audit report and (2) the timing of
communicating the material misstatement to users of the financial
statements. This capping report, which summarizes the results of our
review of the nine agencies, provides our overall observations on their
transparency and timeliness, and includes governmentwide recommendations
based on our work at these agencies.

6GAO, Financial Statement Restatements: Trends, Market Impacts, Regulatory
Responses, and Remaining Challenges, GAO-03-138 (Washington, D.C.: Oct. 4,
2002).

7Pub. L. No. 107-204, 116 Stat. 745 (July 30, 2002).

8Financial Accounting Standards Board, Statement of Financial Accounting
Standards No. 154, Accounting Changes and Error Corrections.

9Form 8-K is the "current report" companies must file with the SEC to
announce major events that shareholders should know about.

                                Results in Brief

The nine agencies we reviewed did not consistently communicate financial
statement restatements. Further, we believe that all nine agencies could
greatly enhance the adequacy, effectiveness, and timeliness of their
restatement disclosures to users. Specifically, we found that

           o  two agencies did not label their financial statements as
           "Restated";

           o  of the six agencies that restated their Statements of Changes
           in Net Position, two of the agencies' restatement presentations
           could be misinterpreted because the agencies' fiscal year 2004
           beginning financial statement balances did not agree with the
           restated fiscal year 2003 ending balances;
           o  all nine agencies' restatement footnotes11 lacked sufficient
           clarity or sufficient detail regarding the nature of the
           restatements and the effect on balances reported in previously
           issued financial statements; and

           o  seven of the nine agencies asserted in their fiscal year 2004
           Management Discussion and Analysis (MD&A) that they had achieved a
           consecutive number of unqualified opinions on their respective
           financial statements. Of these, six did not acknowledge
           restatements to certain of these financial statements in the
           intervening years, which we believe is misleading to users.

           We also found transparency issues with all nine agencies' audit
           reports related to the disclosure of all the essential information
           that would clearly explain the restatement. Specifically, we found
           that

                        o  seven of the nine audit reports did not provide a
                        statement that the previously issued audit report was
                        withdrawn12 and replaced by the opinion on the
                        restated financial statements and

                        o  three of the nine audit reports either did not
                        disclose the restatement or refer to the restatement
                        footnote in the financial statements.

           With regard to the timely communication of material misstatements
           affecting previously issued financial statements and restatement
           of such financial statements, we found that

                        o  three of the nine agencies identified potential
                        material misstatements prior to the fourth quarter of
                        fiscal year 2004 and did not timely communicate that
                        a potential material misstatement had been identified
                        to either their auditor or to the users of the
                        financial statements,

                        o  six of the nine agencies identified potential
                        material misstatements in their fiscal year 2003
                        financial statements after the third quarter of
                        fiscal year 2004 but before that year's comparative
                        financial statements were issued and did not timely
                        communicate that a potential material misstatement
                        had been identified to the users of the financial
                        statements, and

                        o  at least one agency's auditor did not advise the
                        agency's management to timely notify users of the
                        financial statements as to the potential material
                        misstatements affecting the agency's previously
                        issued financial statements.

           The primary contributing factor for these issues was insufficient
           guidance available at the time to both the agencies' management
           and their respective auditors for disclosure of the restatements
           and the timeliness of such disclosures.

           Although the guidance available did not provide explicit details
           for disclosing restatements, we believe that information regarding
           restatements should be disclosed in a transparent and timely
           manner consistent with the qualitative characteristics of
           information in financial reports described in Statement of Federal
           Financial Accounting Concepts (SFFAC) No. 1.13 In our view, more
           detailed accounting and auditing guidance on how to satisfy the
           financial reporting characteristics outlined in SFFAC No. 1 as it
           relates to the disclosure of restatements would have been helpful.
           Nevertheless, a number of federal agencies included information in
           their restatement disclosures that improved the transparency of
           the restatement. For example, during fiscal year 2004, seven of
           the nine agencies labeled their restated financial statements as
           "Restated," although not expressly required by accounting
           standards at that time. In addition, during fiscal year 2005, we
           found that one agency, the Department of State (State), went far
           beyond guidance available for agency management and timely
           notified its users not to rely on its fiscal year 2004 comparative
           financial statements and the related audit report because of a
           potential material misstatement in the financial statements.
           State's action serves as a model for what we believe is
           appropriate for fully and timely notifying users of potential
           material misstatements.

           During our review, OMB revised Circular No. A-136, Financial
           Reporting Requirements,14 which provides additional guidance to
           federal agencies' management regarding disclosure of restatements
           to previously issued financial statements. The revised OMB
           Circular No. A-136, issued August 23, 2005,15 addresses many of
           our concerns regarding the agencies' disclosure of restatements.
           In addition, OMB issued OMB Bulletin No. 06-03, dated August 23,
           2006, which provided additional guidance concerning (1) audit
           report language when the financial statements are restated, (2)
           actions the auditor should take when previously issued audit
           reports are not reliable due to material misstatements, and (3)
           the timing of the restated financial statements and audit reports.
           However, we believe that additional restatement guidance is needed
           for both the agencies' management and their respective auditors.
           As such, this report contains 11 recommendations to assist OMB in
           updating OMB Circular No. A-136 as well as OMB Bulletin No. 06-03
           to further improve guidance to agencies' management and the
           agencies' respective auditors regarding the timely disclosure of
           material misstatements in previously issued financial statements
           and the presentation and disclosure of restatements.

           In oral comments on a draft of this report, OMB stated that it
           would take our recommendations under advisement, but that there
           were no current plans to update guidance that has been recently
           issued.16 OMB also noted that any future plans to update guidance
           would carefully consider issues already currently being addressed
           by the American Institute of Certified Public Accountants' (AICPA)
           Codification of Auditing Standards. In addition, OMB provided some
           technical comments, which we have incorporated as appropriate.

           As noted in this report, we found inconsistent communications and
           insufficient disclosures of financial statement restatements by
           agency management and their auditors. As such, we reiterate our
           concern that it is critical for OMB to timely offer separate,
           though complementary, guidance to agency management and to agency
           auditors that provides more explicit and detailed guidance
           concerning their respective roles and responsibilities when an
           actual or potential material misstatement is identified in
           previously issued financial statements. Separate guidance is
           important because agency management and agency auditors have
           different roles and responsibilities. For example, management is
           responsible for preparing the financial statements and adjusting
           them to correct any material misstatements. The auditor is
           responsible for expressing or disclaiming an opinion on the
           financial statements prepared by management. The auditor has
           certain additional responsibilities should management not properly
           respond to actual or potential material misstatements.

           Background
			  
			  Federal agencies' management responsibilities for their financial
           statements include, among other things, preparing the financial
           statements in conformity with GAAP and establishing and
           maintaining internal controls over financial reporting. Auditors
           of these financial statements are required to plan and perform
           their audits to obtain reasonable assurance about whether the
           financial statements are free of material misstatement. While
           restatements to previously issued financial statements can happen
           and may not be surprising given weaknesses in the financial
           reporting environment at many federal agencies, inherently,
           restatements raise questions about the reliability of other
           information in previously issued financial statements. In
           addition, frequent restatements to correct misstatements can
           undermine public trust and confidence in both the entity and all
           responsible parties. Adequate transparency and timely notification
           of restatements are essential to help preclude users of agencies'
           financial statements and the related audit reports from
           inadvertently relying on inaccurate information and allow them to
           make more informed and relevant decisions.

           According to SFFAC No. 1, the primary intended users of federal
           agencies' financial reports are citizens, the Congress, federal
           executives, and federal program managers. 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, especially those federal programs that affect
           their well-being. The Congress uses the agencies' financial
           statements to monitor and evaluate the efficiency and
           effectiveness of federal programs. Federal executives, such as
           central agency officials at OMB and the Department of the Treasury
           (Treasury), use the federal agencies' financial statements to
           oversee government spending. Specifically, 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 uses the
           agencies' financial statements and the work of their respective
           auditors during its annual audit of the CFS. Federal program
           managers also use agencies' financial statements as a tool for
           managing their respective agencies' operations within the limits
           of the spending authority granted by the Congress.

           Objectives, Scope, and Methodology
			  
			  The objectives of our review were to determine the transparency
           and timeliness of the restatement disclosures by the nine CFO Act
           agencies' management and their respective auditors. For the nine
           agencies we reviewed, we interviewed the preparers and auditors of
           the agencies' fiscal year 2003 financial statements, including
           staff from the agencies' Offices of Inspector General (OIG), and
           we obtained and reviewed relevant audit documentation. Because the
           OIGs typically contracted with various independent public
           accountants (IPA) to audit the agencies' financial statements, we
           expanded our contacts to include such IPAs. Our work was not
           designed to and we did not test the accuracy or appropriateness of
           the restatements. In addition, our review did not include
           restatements17 reported in fiscal year 2005 financial statements
           since such financial statements were issued during November 2005,
           one month after the completion of our fieldwork. With respect to
           the two key areas, we reviewed the nine agencies' fiscal years
           2004 and 2003 comparative financial statements and the related
           audit reports to determine, among other things, whether the

                        o  appropriate columns of the agencies' restated
                        financial statements were labeled "Restated";
                        o  fiscal year 2003 ending balance agreed with the
                        fiscal year 2004 beginning balance on the agencies'
                        Statement of Changes in Net Position, if restated;

                        o  agencies' restatement footnotes were properly
                        labeled;

                        o  agencies asserted in their MD&A that they had
                        received a consecutive number of clean audit
                        opinions, and if so, whether they disclosed that
                        certain of their previously issued financial
                        statements were subsequently restated to correct for
                        a material misstatement;

                        o  audit reports referred the reader to the agencies'
                        restatement footnote;

                        o  agencies timely notified their auditors and users
                        of their financial statements of the material
                        misstatement and plans for correcting the
                        misstatement in the financial statements; and

                        o  auditors were aware of a material misstatement to
                        previously issued financial statements prior to the
                        beginning of the fourth quarter of the following
                        fiscal year and whether the amount and effect were
                        known, and if so, did the auditors advise the
                        agencies' management to reissue the financial
                        statements.

           For this capping report, which is based on our review of the nine
           federal agencies that reported restatements in fiscal year 2004
           financial statements, we considered certain accounting and
           auditing standards that were applicable to fiscal year 2004
           federal financial reporting as well as accounting standards that
           were issued subsequent to fiscal year 2004. These standards
           consist of the Federal Accounting Standards Advisory Board's
           (FASAB) Statement of Federal Financial Accounting Standards
           (SFFAS) No. 15, Management's Discussions and Analysis; SFFAS No.
           21, Reporting Corrections of Errors and Changes in Accounting
           Principles; FAS No. 16, Prior Period Adjustments; FAS No. 154,
           Accounting Changes and Error Corrections; and the AICPA's
           Codification of Auditing Standards, AU section 110,
           Responsibilities and Functions of the Independent Auditor, AU
           section 420, Consistency of Application of Generally Accepted
           Accounting Principles, AU section 508, Reports on Audited
           Financial Statements, and AU section 561, Subsequent Discovery of
           Facts Existing at the Date of the Auditor's Report. We also
           considered the following OMB guidance: OMB Bulletins No. 06-03 and
           No. 01-02, Audit Requirements for Federal Financial Statements;
           OMB Bulletin No. 01-09, Form and Content of Agency Financial
           Statements; and OMB Circular No. A-136, Financial Reporting
           Requirements.18

           We performed our detailed review and analysis of the fiscal year
           2003 restatements reported in agencies' fiscal year 2004 financial
           statements from December 2004 to October 2005. Between September
           2005 and January 2006, we issued reports to five of the nine CFO
           Act agencies that had received unqualified audit opinions on, but
           subsequently restated in fiscal year 2004, their originally issued
           fiscal year 2003 financial statements. In conjunction with our
           fiscal year 2005 CFS audit, we identified continued restatements
           of previously issued agency financial statements and the need for
           additional guidance to agencies and their auditors governmentwide.
           Our work was performed in accordance with GAGAS.

           We requested comments on a draft of this report from the Director
           of OMB or his designee. OMB provided oral comments, which are
           discussed in the Agency Comments and Our Evaluation section of
           this report.

           Insufficient and Inconsistent Disclosure of Financial Statement
			  Restatements by Certain Federal Agencies and Their Auditors
			  
			  During our review of the nine CFO Act agencies' restatements
           reported in fiscal year 2004, we identified issues with the
           disclosures made by those agencies and their respective auditors
           regarding the restatements. The primary contributing factor for
           these disclosure issues was insufficient guidance available at the
           time to both the agencies' management and their auditors for
           disclosing the restatements.

           Although the available guidance did not provide explicit details
           for disclosing restatements, we believe that information regarding
           restatements should be disclosed in a transparent and timely
           manner consistent with the qualitative characteristics of
           information in financial reports described in SFFAC No. 1. In our
           view, more detailed accounting and auditing guidance on how to
           satisfy the financial reporting characteristics in SFFAC No. 1 as
           it relates to the disclosure of restatements would have been
           helpful. Regardless, as discussed later in the report, several
           agencies included information in their restatement disclosures
           that improved the transparency of the restatement.

           Given the issues we identified in our review of restatements
           reported in fiscal year 2004 financial statements, we believe it
           would be appropriate to offer more explicit or detailed guidance
           for how agency management and their respective auditors should
           disclose restatements. Specifically, although SFFAS No. 21
           required that the nature of an error in previously issued
           financial statements and the effect of its correction on relevant
           balances be disclosed, the standard did not provide a detailed
           explanation of the type of information that should be disclosed or
           what the nature of an error means. OMB Bulletin No. 01-09, which
           specifies the form and content for federal financial statements,
           also did not provide specific guidance on how an agency's
           management should disclose restatement information in its
           financial statements. As for the auditor's disclosure of the
           agency's restatements in its audit report, AU section 561 only
           stated that the audit report usually should refer to the note to
           the financial statements that describes the restatement. Thus, if
           for no other reason than avoiding interpretation issues as to how
           much disclosure and in what form is appropriate, we believe that
           guidance to agency auditors should be enhanced to attain some
           added level of uniform treatment regarding the disclosure of
           restatements.

           Issues Regarding Agenciesï¿½ Restatement Disclosures
			  
			  We identified the following four issues related to the agencies'
           reporting of the restatements.

           Labeling of Restated Financial Statements
			  
			  While guidance available during fiscal year 2004 did not expressly
           require agencies to label the columns of restated financial
           statements as "Restated," seven of the nine agencies labeled their
           financial statements as such. Such labeling is a common practice
           in reporting restated financial statements. Two of the nine
           agencies did not label their financial statements as "Restated,"
           and as a result, users of such statements may be unaware that a
           restatement occurred.

           OMB Circular No. A-136 was revised during fiscal year 2005 to
           provide additional guidance for disclosing restatements; however,
           it does not require agencies to label their financial statements
           as "Restated." In our view, revising OMB Circular No. A-136 to
           require agencies to label the columns of the restated financial
           statements as "Restated" would make the existence of restated
           financial statements more evident to the readers of the financial
           statements.

           Restatements to Certain Agenciesï¿½ Statement of Changes in Net Position
			  
			  We also found issues regarding certain agencies' restated
           Statement of Changes in Net Position. Of the six agencies that
           restated their originally issued fiscal year 2003 Statements of
           Changes in Net Position to correct for material misstatements, two
           of the restatement presentations could be misinterpreted because
           the fiscal year 2004 beginning balances did not agree with the
           restated fiscal year 2003 ending balances. Instead of carrying
           forward the restated fiscal year 2003 ending balance to the fiscal
           year 2004 beginning balance, these two agencies made prior period
           adjustments to the fiscal year 2004 beginning balances to reflect
           the restated fiscal year 2003 ending balances. We believe that a
           clearer presentation on the agencies' fiscal years 2004 and 2003
           comparative Statement of Changes in Net Position would have been
           to carry forward the restated fiscal year 2003 ending balances and
           present them as the fiscal year 2004 beginning balances instead of
           presenting prior period adjustments in the fiscal year 2004
           column.

           Although authoritative guidance available during fiscal year 2004
           did not expressly prohibit agencies from reflecting prior year
           restatements as adjustments to the current year's beginning
           balances on the Statement of Changes in Net Position, we found
           that the other four agencies' restated fiscal year 2003 ending
           balances agreed with the fiscal year 2004 beginning balances on
           their Statement of Changes in Net Position. The current version of
           OMB Circular No. A-136 includes guidance from SFFAS No. 21, which
           states that the adjustment should be made to the beginning balance
           of cumulative results of operations, in the Statement of Changes
           in Net Position for the earliest period presented. In our view,
           OMB Circular No. A-136 would be enhanced if it explicitly stated
           that the current year unadjusted beginning balances on the
           Statement of Changes in Net Position are to agree with the
           restated ending balances on the prior year's statement (i.e., that
           adjustments are to be made only to the prior year and carried
           forward as restated).

           Agenciesï¿½ Restatement Footnotes
			  
			  In our view, all nine of the agencies' restatement footnotes
           lacked sufficient clarity or sufficient detail regarding the
           restatements in at least one of the following two areas: (1) the
           title of the footnote or (2) the content of the footnote.

           For five agencies, the title of the restatement footnote did not
           reflect the existence of a restatement. Specifically, three
           agencies titled their restatement footnotes as either "Prior
           Period Adjustments" or "Prior Period Reclassification," which
           could be misinterpreted since the changes to the financial
           statements represented restatements because of material
           misstatements rather than prior period adjustments19 or prior
           period reclassifications.20 The other two agencies did not include
           separate footnotes disclosing the restatement information.
           Instead, one agency provided the restatement information under its
           "Significant Accounting Policies" and the other included it under
           its "Statement of Changes in Net Position" and its "Statement of
           Budgetary Resources" notes. The remaining four agencies
           appropriately titled their restatement disclosures by entitling
           their footnote "Restatement."

           With respect to restatement footnote content, five clearly
           explained the misstatement and reason for the restatement while
           the other four agencies did not. Accordingly, it was not clear if
           these four agencies' misstatements were attributed to errors in
           recognition, measurement, presentation, or disclosure in financial
           statements resulting from mathematical mistakes, mistakes in the
           application of GAAP, or oversight or misuse of facts that existed
           at the time the financial statements were prepared. In addition,
           one of the nine agencies did not disclose the specific year(s)
           being restated, while two other agencies did not disclose all of
           the financial statements impacted by the restatements.

           Further, we also believe some additional language should be
           included in related footnotes. Specifically, in our view, a
           sufficient restatement footnote would also include (1) the
           specific amount(s) of the material misstatement(s) and the related
           effect(s) on the previously issued financial statement(s) (e.g.,
           year(s) being restated and the specific financial statement(s)
           affected and line items restated); (2) the overall impact the
           restatement has on the current year financial statements (e.g.,
           the change in overall net position, change in the audit opinion);
           and (3) a discussion of the corrective actions taken by the
           agency's management. Although six agencies appropriately disclosed
           the amounts being restated, the remaining three did not disclose
           the specific line items restated and the related amounts. In
           addition, five agencies did not disclose the effect of the
           restatement on the financial statements as a whole. Further, none
           of the nine agencies' restatement footnotes discussed the actions
           taken by the agency's management after discovering the
           misstatement, such as measures taken to better prevent similar
           misstatements from occurring in the future (e.g., improvements in
           internal controls).

           Authoritative guidance available during fiscal year 2004 did not
           provide explicit guidance to the agencies as to what information
           should be included in the agencies' footnotes or how the
           restatement note should be titled. Revisions made to OMB Circular
           No. A-136 address a number of these areas. Specifically, OMB
           Circular No. A-136 now requires agencies to provide restatement
           information in a separate note entitled "Restatements." In
           addition, regarding content of the note, the revised circular
           calls for the following information to be included in the note:
           the nature of the error and the reason for the restatement, the
           year(s) being restated, which financial statements are impacted,
           the amounts being restated, and the effect of the restatement on
           the financial statements as a whole (i.e., change in overall net
           position, change in audit opinion, etc.). Further, per the revised
           OMB Circular No. A-136, agencies should discuss the actions
           management took after discovering the error.

           The additional requirements in OMB Circular No. A-136 address many
           of our concerns with the transparency of the restatement footnote.
           We did, though, identify three areas where OMB Circular No. A-136
           could further enhance transparency. The first is to clarify that
           when agencies disclose the amounts being restated, it is important
           that they also disclose the specific line items restated and the
           related amounts. In our view, this additional information will
           allow the readers of the restated financial statements to more
           clearly see how the restatement affected such statements. The
           second is to define the meaning of the "nature" of an error. The
           third is to explicitly state what type of information should be
           provided when discussing the actions management took after
           discovering the error.

           Disclosure of Restatements in Agenciesï¿½ Managementï¿½s Discussion
			  and Analysis
			  
			  We also found that certain agencies' presentation of restatements
           in their MD&A could be misleading. Seven of the nine agencies we
           reviewed stated in their fiscal year 2004 MD&A that they had
           achieved a consecutive number of unqualified opinions on their
           respective financial statements. However, six did not acknowledge
           that one or more of these financial statements had been restated
           in the intervening years to correct for material misstatements. We
           believe stating that there have been consecutive years of
           unqualified audit opinions without the appropriate context could
           be misleading to the reader of the financial statements. It
           erroneously conveys an impression of consistent, accurate
           financial reporting over a period of time, when in fact this was
           not the case because subsequently, the financial statements and
           the opinion were found to be incorrect.

           According to SFFAS No. 15, Management's Discussions and Analysis,
           management should have great discretion regarding what to say in
           its MD&A. At the same time, the standard also states that the
           pervasive requirement is that the MD&A not be misleading. In our
           view, it is misleading for an agency to state in its MD&A that it
           has received a consecutive number of unqualified opinions on its
           financial statements when one or more of its financial statements
           within that time frame were subsequently restated. In our view,
           agencies having restated their financial statements should either
           refrain from such claims or clearly disclose in their MD&A which
           of the agency's prior year financial statements, as originally
           issued, were materially misstated and subsequently restated.
           Although standards do not specifically state that agencies shall
           disclose restatement information in their MD&A, we found that one
           of the seven agencies did state that it had received a clean audit
           opinion for 7 consecutive years but appropriately disclosed that
           its fiscal year 2003 financial statements were restated to correct
           misstatements.

           Issues Regarding Auditorsï¿½ Restatement Disclosures
			  
			  During our review, we found issues regarding how agency auditors
           disclosed the agencies' restatements in their audit reports.
           According to AU section 561, the restatement footnote in the
           agency's financial statements "usually should" be referred to in
           the audit report, but given the latitude, such disclosure is not
           an across-the-board requirement. In any report on financial
           statements, the auditor has the discretion to add a separate
           paragraph to the audit report to emphasize a matter regarding the
           financial statements. In our view, such matters include the effect
           of the material misstatements on previously audited financial
           statements and the accompanying audit report. Also, we believe
           that if the agency's restatement footnote does not provide a clear
           and adequate description of the restatement, then the auditor
           should go beyond merely referencing the restatement footnote and
           add a separate paragraph to the audit report that provides
           additional details regarding the effects of the restatement and
           should consider whether it is necessary to modify the audit
           opinion.

           In our view, none of the nine agencies' audit reports we reviewed
           sufficiently disclosed all the essential information that would
           clearly explain the restatement. Specifically, we found that

                        o  seven of the nine audit reports did not provide a
                        statement that the previously issued audit report was
                        withdrawn and replaced by the opinion on the restated
                        financial statements,

                        o  three of the nine audit reports either did not
                        disclose the restatement or include a reference to
                        the agency restatement footnote in the financial
                        statements,21 and

                        o  none of the nine agencies provided a sufficient
                        description of the restatement (i.e., the nature and
                        cause of the misstatement, year(s) being restated,
                        financial statements and line items impacted,
                        specific amount(s) of the material misstatement(s)
                        and the related effects on the previously issued
                        financial statements, and actions management took
                        after discovering the misstatement) in the notes to
                        their financial statements and none of these
                        agencies' auditors compensated for this by providing
                        such information in their audit reports.

           In our view, the auditor plays an important role in ensuring
           proper disclosure of restatements. Accordingly, if any of the
           prior year financial statements are restated and management did
           not already provide a sufficient description of the restatement in
           the note(s) to the financial statements, the audit report should
           include such information. In addition, although none of the nine
           agencies' auditors disclosed misstatements of unknown amounts, we
           believe that if at the time of issuance of the audit report, a
           material misstatement or potential material misstatement has been
           identified in any of the prior years' financial statements but the
           specific amount of the misstatement and the related effects of
           such are not yet known, it is important for the auditor to
           disclose the situation in its audit report and modify its opinion
           or disclaim an opinion on the prior year financial statements as
           appropriate.

           Timely Communication of Material Misstatements to Users of
			  Previously Issued Financial Statements
			  
			  We also identified issues with the timeliness of management and
           auditor communication regarding material misstatements affecting
           certain agencies' previously issued financial statements. We
           attributed these issues to a combination of the lack of specific
           guidance at that time for both agencies management and their
           respective auditors and the lack of compliance with the related
           accounting and auditing standards that were in effect during
           fiscal year 2004.

           During fiscal year 2004, neither OMB Bulletin No. 01-09 nor SFFAS
           No. 21, which apply primarily to agency management, provided
           specific guidance on the timely investigation and reporting of a
           material misstatement or potential material misstatement in a
           previously issued financial statement following its discovery. The
           guidance available to auditors at that time was AU section 561 and
           OMB Bulletin No. 01-02, which provided guidance to the agencies'
           auditors regarding the timely communication of restatements for
           corrections of misstatements. While this audit guidance conveyed
           the intent of timely communication, it did not provide much
           guidance for how the agencies' management or their respective
           auditors should timely communicate such restatements.

           OMB Bulletin No. 01-02 stated that there shall be open and timely
           communication throughout the audit process between the agencies'
           management and their auditors, which includes potential audit
           findings, materially misstated or unsupported amounts in the
           financial statements, and material weaknesses in internal control.
           The bulletin did not provide guidance for what the auditor should
           communicate to management for when and how an actual or potential
           restatement should be disclosed to the users of the agency's
           financial statements. With respect to the auditor's
           responsibilities for timely communication, AU section 561 states
           that consideration should be given to, among other things, the
           "time elapsed" since the erroneous financial statements were
           issued. According to AU section 561, when the auditor has
           concluded that action should be taken to prevent future reliance
           on the audit report, the auditor should advise the auditee to make
           appropriate disclosure of the newly discovered facts and their
           impact on the financial statements to persons who are known to be
           currently relying or who are likely to rely on the financial
           statements and the related auditor's report. AU section 561 also
           states that if an auditor determines that issuance of financial
           statements accompanied by the audit report for a subsequent period
           is "imminent," appropriate disclosures can be made in such
           statements rather than by separately issuing the restated
           financial statements. However, guidance available during fiscal
           year 2004, AU section 561 and OMB Bulletin No. 01-02,22 did not
           define "time elapsed" or "imminent." In addition, existing
           standards and guidance do not provide sufficient explicit or
           detailed guidance to management and auditors regarding ensuring
           the timely disclosure of material misstatements affecting
           previously issued financial statements.

           Issues Regarding Timeliness of Managementï¿½s Communication of
			  Misstatements to Auditors and Users
			  
			  In our view, none of the agencies timely communicated that a
           potential material misstatement had been identified to either
           their auditor or to the users of the financial statements. Agency
           management is responsible for reporting key information in a
           timely manner, including timely notification of known material or
           potential material misstatements in previously issued financial
           statements.

           During fiscal year 2004, OMB Bulletin No. 01-02 called for
           communication between the agencies' management and their auditors,
           but it did not provide details for disclosing restatements to
           users of agency financial statements. In addition, as noted above,
           neither OMB Bulletin No. 01-09 nor SFFAS No. 21 provided specific
           guidance on the timely investigation and reporting of a material
           misstatement or potential material misstatement in a previously
           issued financial statement following its discovery. Our review of
           the nine CFO Act agencies that restated certain of their fiscal
           year 2003 financial statements found that three of these agencies
           identified potential material misstatements prior to the beginning
           of the fourth quarter of fiscal year 2004, and in our view, did
           not timely communicate that a potential misstatement had been
           identified either to their auditors or to the users of their
           financial statements. The remaining six agencies identified
           potential material misstatements after the third quarter of fiscal
           year 2004 but before that year's comparative financial statements
           were issued. These six agencies, in our view, also did not timely
           communicate the potential material misstatements to the users of
           their financial statements since they did not notify the users of
           the potential material misstatement prior to the issuance of the
           restated fiscal year 2003 financial statements during fiscal year
           2004.

           We believe that the current version of OMB Circular No. A-136, if
           properly implemented, should address many of our concerns
           regarding agencies' timely communication of restatements. For
           example, according to this version of OMB Circular No. A-136,
           "management shall assume responsibility for any false or
           misleading information in the financial statements, or omissions
           that render information made in the financial statements
           misleading. As such, as soon as possible after errors are
           detected, management shall notify their auditors and inform their
           primary users of their financial statements of the error and plans
           for correcting it in the financial statements ... it is imperative
           that management work with their auditor as soon as the error is
           detected to assist the auditor in any actions that need to be
           taken."

           These are important advances. We do, though, have some remaining
           concerns regarding the adequacy of guidance to agencies relating
           to the timely communication of material misstatements in
           previously issued financial statements. Specifically, we believe
           it is important for subsequently discovered material misstatements
           and potential material misstatements be disclosed to OMB in the
           agencies' quarterly financial statements for the reporting period
           in which the misstatements were discovered. In our view, agencies
           need to report on the misstatement within a reasonable time period
           following the discovery of the misstatement. In particular, if the
           specific amount of a material misstatement and the related effect
           of such on the previously issued financial statements are known
           and the issuance of the subsequent period audited financial
           statements is not imminent, then we believe it is important that
           the agencies promptly (1) reissue the most recently issued fiscal
           year financial statements before issuing the current year's
           financial statements and (2) communicate the reissuance (a) in
           writing to the Congress, OMB, Treasury, and GAO; and (b) to the
           public on the Internet pages where the agencies' audited financial
           statements that were affected by the material misstatements were
           published. If a material misstatement is identified when issuance
           of the subsequent period audited financial statements is imminent,
           we believe it is important that the agencies (1) issue restated
           financial statements as part of the current year's comparative
           financial statements and (2) communicate the restatement (a) in
           writing to the Congress, OMB, Treasury, and GAO; and (b) to the
           public on the same Internet page where the agencies' audited
           financial statements that were affected by the material
           misstatements were published.

           Further, in our view, if at any time an agency identifies a
           material misstatement or potential material misstatement and the
           effects of it on the financial statements are not known or cannot
           be determined without a prolonged investigation, the agencies
           should timely notify persons that are known to be relying or who
           are likely to rely on the previously issued financial statements
           and the related audit report that the (1) previously issued
           financial statements will or may be restated and therefore, (2)
           the related audit report is no longer reliable. It is important
           that the agencies include the Congress, OMB, Treasury, and GAO in
           any such notification and notify the public by posting such
           notification on the same Internet pages where the agencies'
           previously issued financial statements that were affected by the
           material or potential material misstatement were published.

           An example of how to appropriately convey this type of information
           is State's communication and disclosure of a potential material
           misstatement in its fiscal year 2004 financial statements.
           Specifically, State identified a potential material misstatement
           during the fourth quarter of fiscal year 2005 and, in our view,
           went beyond the then existing guidance and appropriately disclosed
           the problem. Guidance available to agency management at that time,
           SFFAS No. 21 and OMB Bulletin No. 01-09, did not provide explicit
           guidance for timely communication of a restatement to users of
           financial statements. State also complied with the revised OMB
           Circular No. A-136, issued August 23, 2005, even though it was not
           effective until the end of fiscal year 2005. Specifically, during
           September 2005, State's CFO timely notified external parties,
           including GAO, to which State's fiscal year 2004 comparative
           financial statements were directly distributed, not to rely on its
           fiscal year 2004 comparative financial statements and the related
           audit report. The notification also stated that State was
           committed to resolving this issue as quickly as possible. State
           also notified the public of this issue in the form of a cautionary
           note on the same Internet pages where the agency's audited
           financial statements that were affected by the material
           misstatement were published. State's cautionary note included a
           statement that such actions were necessary because State recently
           became aware of a potential material misstatement affecting the
           previously issued financial statements and the related audit
           report. State noted that due to the need for a complete and
           thorough analysis, the complexity of the matters involved, and the
           accelerated financial reporting requirements, State was unable to
           satisfy the independent auditors by November 15 as to the amount
           of the potential material misstatement. As a result, the
           independent auditors issued a qualified opinion on the fiscal year
           2005 and 2004 financial statements. State's CFO also sent a
           subsequent letter to GAO on December 23, 2005, to inform us that
           the independent auditors had satisfied themselves about the
           amounts presented and the auditor updated its opinion on the
           fiscal year 2005 and 2004 financial statements from a qualified to
           an unqualified opinion. State was fully transparent in its reports
           of the restatement in all respects and showed how disclosing the
           restatement should be done. As such, in our view, State's actions
           serve as a model for full and timely notification of a potential
           material misstatement found in a previously issued financial
           statement when identified after the third quarter of the current
           fiscal year and before the current year's comparative financial
           statements are issued.

           Issues Regarding Timeliness of Certain Auditorsï¿½ Restatement
			  Disclosures
			  
			  Auditors play a critical role in helping to ensure that users of
           financial statements are timely notified of material misstatements
           affecting previously issued financial statements and restatement
           of such financial statements.

           AU section 561, guidance available during fiscal year 2004,
           requires that auditors consider the "time elapsed" since the
           financial statements were issued when a material misstatement is
           discovered. According to AU section 561, if an auditor determines
           that issuance of financial statements accompanied by the audit
           report for a subsequent period is "imminent," appropriate
           disclosures can be made in such statements rather than in reissued
           statements. However, neither "time elapsed" nor "imminent" is
           defined in AU section 561. We found that at least one of the
           auditors of the three agencies that had discovered misstatements
           prior to the fourth quarter of the current fiscal year did not
           advise its respective agency to make such a disclosure because (1)
           in May 2004 the auditor did not think that there were any users
           who would still be relying on the fiscal year 2003 financial
           statements and the related audit report and (2) the auditor
           considered issuance of the fiscal years 2004 and 2003 comparative
           financial statements to be imminent.23 We have concerns that,
           without notification, anyone who may have been relying on the
           fiscal year 2003 financial statements would not have known for
           more than 5 months that the agency's originally issued financial
           statements, which received an unqualified opinion, were materially
           misstated and should not be relied on.

           In our view, existing auditing standards and guidance, including
           OMB Bulletin No. 06-03, while conveying the need for appropriate
           notifications, do not provide sufficient explicit or detailed
           guidance to auditors regarding ensuring the timely disclosure of
           material misstatements affecting previously issued financial
           statements. Our position is that when a material misstatement or
           potential material misstatement affecting previously issued
           financial statements and the related audit report is identified,
           the auditor has a responsibility to advise the agency's management
           to timely notify users such as the Congress, OMB, Treasury, and
           GAO in writing as well as the public and clearly disclose the
           situation to them. If the agency's management does not timely
           provide adequate disclosure to the relevant users, the auditor has
           the responsibility to do so.

           We believe that it is also important that the auditor advise the
           agency's management of its responsibility to determine the
           specific amount of the material misstatement or potential material
           misstatement and the related effects of such on the previously
           issued financial statements as soon as reasonably possible. In
           those cases where the specific amount of the material misstatement
           and the related effects of such on a previously issued financial
           statement are known and issuance of the subsequent period audited
           financial statements is not imminent, we believe that the auditor
           would need to also advise the agency's management to promptly
           reissue the most recently issued fiscal year financial statements
           before issuing the current fiscal year financial statements and to
           communicate the reissuance to relevant users in writing as well as
           the public to clearly disclose the situation to them. If the
           agency's management does not reissue the financial statements or
           communicate the reissuance as required, our position is that the
           auditor has the responsibility to notify the Congress, OMB,
           Treasury, and GAO in writing as well as any other users known to
           be relying on the previously issued financial statements. If the
           specific amount of the material misstatement and the related
           effects of such on a previously issued financial statement are
           known and issuance of the subsequent period audited financial
           statements is imminent, it is important that the auditor advise
           the agency's management to issue restated financial statements as
           part of the current year comparative financial statements and
           disclose restatements in the audit report. If the specific amount
           of the misstatement and the related effect of such on a previously
           issued financial statement remain unknown when the current year
           financial statements are issued, it is necessary that the auditor
           disclose such information when issuing the audit report and modify
           or disclaim the opinion on the previously issued financial
           statements as appropriate.

           Conclusions
			  
			  The issues we identified regarding the transparency and timeliness
           of restatement disclosures primarily resulted from insufficient
           guidance available during fiscal year 2004 to both the agencies'
           management and their respective auditors for disclosure of the
           restatements and the timeliness of such disclosures. It will be
           important that those agencies needing, in the future, to restate
           their prior year financial statements ensure the adequacy of the
           disclosure and presentation of such restatements as well as timely
           notifying users known to be relying on the previously issued
           financial statements. It will also be important that the agencies'
           financial statements and the related audit reports provide
           sufficient detail so that the reader will be able to gain at least
           a basic understanding of why the agencies needed to restate their
           previously issued financial statements and the effects of such on
           the agencies' previously issued financial statements. The revision
           of OMB Circular No. A-136 during fiscal year 2005 addressed many
           of our concerns regarding the agencies' disclosure of
           restatements; however, additional guidance is still needed. In
           this regard, we are making recommendations for further revisions
           to OMB Circular No. A-136 as well as OMB Bulletin No. 06-03. We
           have provided our views, as outlined in appendix I, on how OMB
           guidance could be further enhanced to ensure that future
           restatement disclosures are uniform and more transparent.

           Recommendations for Executive Action
			  
			  We recommend that the Director of OMB direct the Controller of
           OMB's Office of Federal Financial Management to incorporate the
           restatement guidance and requirements, as detailed in appendix I,
           into Circular No. A-136 to assist OMB in addressing the issues we
           found with the agencies' restatement disclosures and the
           timeliness of such disclosures. Appendix I incorporates seven
           recommendations as specific changes to Circular No. A-136 that
           focus on the

                        o  timely disclosure by agency management of material
                        misstatement(s) or potential material misstatement(s)
                        and the related effect(s) of such in the previously
                        issued financial statements and

                        o  presentation and disclosure of restatements in the
                        agencies' MD&A and financial statements and related
                        footnotes.

           We also recommend that the Director of OMB direct the Controller
           of OMB's Office of Federal Financial Management to incorporate the
           restatement guidance and requirements, as detailed in appendix I,
           into Bulletin No. 06-03 to assist OMB in addressing the issues we
           found with auditors' restatement disclosures and the timeliness of
           such disclosures. Appendix I incorporates four recommendations as
           specific changes to Bulletin No. 06-03 that focus on the

           Agency Comments and Our Evaluation
			  
			  In oral comments on a draft of this report, OMB stated that it
           would take our recommendations under advisement, but that there
           were no current plans to update guidance that has been recently
           issued.24 OMB also noted that any future plans to update guidance
           would carefully consider issues already currently being addressed
           by the AICPA's Codification of Auditing Standards. In addition,
           OMB provided some technical comments, which we have incorporated
           as appropriate.

           As noted in this report, we found inconsistent communications and
           insufficient disclosures of financial statement restatements by
           agency management and their auditors. As such, we reiterate our
           concern that it is critical for OMB to timely offer separate,
           though complementary, guidance to agency management and to agency
           auditors that provides more explicit and detailed guidance
           concerning their respective roles and responsibilities when an
           actual or potential material misstatement is identified in
           previously issued financial statements. Separate guidance is
           important because agency management and agency auditors have
           different roles and responsibilities. For example, management is
           responsible for preparing the financial statements and adjusting
           them to correct any material misstatements. The auditor is
           responsible for expressing or disclaiming an opinion on the
           financial statements prepared by management. The auditor has
           certain additional responsibilities should management not properly
           respond to actual or potential material misstatements.

           This report contains recommendations to the Director of OMB. The
           head of a federal agency is required by 31 U.S.C. S: 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 also must 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 Secretary of the Treasury and the Fiscal Assistant
           Secretary of the Treasury. 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 OMB and the nine CFO Act agencies' management and
           their respective auditors throughout our work. We look forward to
           continuing to work with your office to help improve financial
           management in the federal government. If you or your staff have
           any questions about the contents of this report, please contact
           Gary T. Engel, Director, Financial Management and Assurance, at
           (202) 512-3406 or by e-mail at [email protected]. Staff
           acknowledgments are provided in appendix II.

           Sincerely yours,

           David M. Walker
			  Comptroller General of the United States

           Appendix I: Recommendations to OMB
			  
			  As noted throughout this report, we believe that additional
           restatement guidance is needed for both the agencies' management
           and their respective auditors. To facilitate in this process, we
           are providing the following 11 requirements that, in our view,
           should be incorporated into Office of Management and Budget (OMB)
           Circular No. A-136 and OMB Bulletin No. 06-03.

           Recommendations Regarding OMB Circular No. A-136
			  
			  GAO recommends that the following requirement be added to sections
           II.4.3.1, II.4.4.1, II.4.5.1, II.4.6.1, and II.4.7.1 of OMB
           Circular No. A-136, Financial Reporting Requirements:

           Agencies shall label restated financial statements as "Restated."

           GAO recommends that the "Management Actions Related to Corrections
           of Errors" subsection of section II.4.5.5 of OMB Circular No.
           A-136, Financial Reporting Requirements, be modified to read as
           follows:

           If the agency's management becomes aware of a material
           misstatement(s) or potential material misstatement(s) affecting a
           previously issued financial statement(s), then the agency's
           management, in coordination with their respective auditor, shall
           do the following:

                        o  auditor's timely disclosure of material
                        misstatement(s) or potential material misstatement(s)
                        and the related effect(s) of such in the previously
                        issued financial statements and

                        o  presentation and disclosure of restatements in the
                        audit report.

                        1. Communicate the following information to those
                        charged with governance, oversight bodies, funding
                        agencies, and others who are relying or are likely to
                        rely on the financial statement(s). This includes
                        communication (1) in writing to the Congress, OMB,
                        Treasury, and GAO; (2) to the public on the Internet
                        pages where the agency's previously issued financial
                        statements that were affected by the material
                        misstatement(s) or potential material misstatement(s)
                        are published; and (3) to OMB in the agency's next
                        quarterly financial statements and in subsequent
                        quarterly financial statements until the specific
                        amount(s) of the material misstatement(s) and the
                        related effect(s) of such on the previously issued
                        financial statement(s) are known and reported:

                        (a) the nature and cause(s) of the known or likely
                        material misstatement(s),

                        (b) the amount(s) of known or likely material
                        misstatement(s) and the related effect(s) on the
                        previously issued financial statement(s) (e.g.,
                        disclosure of the specific financial statement(s) and
                        line item(s) affected). If this information is not
                        known, then the disclosure includes information that
                        is known and a statement that management cannot
                        determine the amount(s) and the related effect(s) on
                        the previously issued financial statement(s) without
                        further investigation, and

                        (c) a notice that (1) a previously issued financial
                        statement(s) will or may be restated1 and, therefore,
                        (2) the related auditor's report is no longer
                        reliable.

                        2. Promptly determine the financial statement effects
                        of the known or potential material misstatement(s) on
                        the previously issued financial statement(s).

                        (a) If the specific amount(s) of the material
                        misstatement(s) and the related effect(s) of such on
                        a previously issued financial statement(s) are known
                        and issuance of the subsequent period audited
                        financial statements is not imminent,2 then the
                        agency's management shall promptly:

                        i. reissue the most recently issued fiscal year
                        financial statements before issuing the current
                        fiscal year's financial statements;

                        ii. communicate the reissuance to those charged with
                        governance, oversight bodies, funding agencies, and
                        others who are relying or are likely to rely on the
                        financial statement(s). This includes communication
                        (a) in writing to the Congress, OMB, Treasury, and
                        GAO and (b) to the public on the Internet pages where
                        the agency's previously issued financial statements
                        that were affected by the material misstatement(s)
                        are published; and

                        iii. disclose the following information, at a
                        minimum, in the agency's restatement footnotes:

                        1. the nature and cause(s) of the misstatement(s)
                        that led to the need for restatement, and

                        2. the specific amount(s) of the material
                        misstatement(s) and the related effect(s) on the
                        previously issued financial statement(s) (e.g.,
                        year(s) being restated, specific financial
                        statement(s) affected and line items restated,
                        actions the agency's management took after
                        discovering the misstatement), and the impact on the
                        financial statements as a whole (e.g., change in
                        overall net position, change in the audit opinion).

                        (b) If the specific amount(s) of the material
                        misstatement(s) and the related effect(s) of such on
                        a previously issued financial statement(s) are known
                        and issuance of the subsequent period audited
                        financial statements is imminent, then the agency's
                        management shall:

                        i. issue restated financial statement(s) as part of
                        the current year's comparative financial statements;

                        ii. communicate the restatement to those charged with
                        governance, oversight bodies, funding agencies, and
                        others who are relying or are likely to rely on the
                        financial statement(s). This includes communication
                        (a) in writing to the Congress, OMB, Treasury, and
                        GAO and (b) to the public on the Internet pages where
                        the agency's previously issued financial statements
                        that were affected by the material misstatement(s)
                        are published; and

                        iii. disclose the following information, at a
                        minimum, in the agency's restatement footnote:

                        1. the nature and cause(s) of the misstatement(s)
                        that led to the need for restatement, and

                        2. the specific amount(s) of the material
                        misstatement(s) and the related effect(s) on the
                        previously issued financial statement(s) (e.g.,
                        year(s) being restated, specific financial
                        statement(s) affected and line items restated,
                        actions the agency's management took after
                        discovering the misstatement), and the impact on the
                        financial statements as a whole (e.g., change in
                        overall net position, change in the audit opinion).

                        (c) If the specific amount(s) of the misstatement(s)
                        and the related effect(s) of such on a previously
                        issued financial statement(s) remain unknown when the
                        current year's financial statements are issued, then
                        the agency's management shall follow section II.4.5.5
                        (1) above and include the following, at a minimum, in
                        its restatement footnote:

                        i. a statement disclosing that a material
                        misstatement(s) or potential material misstatement(s)
                        affects a previously issued financial statement(s),
                        but the specific amount(s) of the misstatement(s) and
                        the related effect(s) of such are not known,

                        ii. the nature and cause(s) of the misstatement(s) or
                        potential misstatement(s),

                        iii. an estimate of the magnitude of the
                        misstatement(s) or potential misstatement(s) and the
                        related effect(s) of such on a previously issued
                        financial statement(s) (e.g., disclosure of the
                        specific financial statement(s) and line items
                        affected) that are known and a statement that the
                        specific amount(s) and the related effect(s) of such
                        cannot be determined without further investigation,
                        and

                        iv. a statement disclosing that a restatement(s) to a
                        previously issued financial statement(s) will or may
                        occur.

           GAO also recommends that the following requirement be added to the
           "Corrections of Errors" subsection of section II.4.5.5 of OMB
           Circular No. A-136, Financial Reporting Requirements:

           The Statement of Changes in Net Position's current year's
           unadjusted beginning balances shall agree with the restated ending
           balances on the agency's prior year's Statement of Changes in Net
           Position.

           GAO recommends that section II.4.10.43, of OMB Circular No. A-136,
           Financial Reporting Requirements, be revised to:

                        o  clarify the definition of the "nature" of an
                        error,

                        o  include an explanation that the disclosure of the
                        "amounts being restated" specifically refers to the
                        disclosure of the specific line items restated and
                        the related amounts, and

                        o  clarify how an agency should specifically further
                        discuss the actions management took after discovering
                        the error.

           GAO recommends that the following requirement be added to section
           II.2.7 of OMB Circular No. A-136, Financial Reporting
           Requirements, which discusses guidance for information included in
           the Management Discussion and Analysis (MD&A):

           Agency's management shall disclose the existence of restatements
           in its MD&A if the agency asserts in its MD&A that it received an
           unqualified opinion on any previously issued financial statement
           and that respective financial statement was subsequently restated.

           Recommendations Regarding OMB Bulletin No. 06-03
			  
			  GAO recommends that section 5.2 of OMB Bulletin No. 06-03, Audit
           Requirements for Federal Financial Statements, be modified to read
           as follows:

           5.2 The nature or amount of known or likely misstatement(s) in
           previously issued audited financial statement(s) may lead the
           auditor to believe that the auditor's report would or could
           reasonably have been affected if the auditor had known of the
           misstatement(s) when the auditor issued the auditor's report. When
           this condition exists, the auditor shall advise management to
           communicate the following information to those charged with
           governance, oversight bodies, funding agencies, and others who are
           relying or are likely to rely on the financial statement(s):

                        o  the nature and cause(s) of the known or likely
                        material misstatement(s),

                        o  the amount(s) of known or likely material
                        misstatement(s) and the related effect(s) on the
                        previously issued financial statement(s) (e.g.,
                        disclosure of the specific financial statement(s) and
                        line item(s) affected). If this information is not
                        known, then the disclosure includes information that
                        is known and a statement that management cannot
                        determine the amount(s) and the related effect(s) on
                        the previously issued financial statement(s) without
                        further investigation, and

                        o  a notice that (1) a previously issued financial
                        statement(s) will or may be restated and, therefore,
                        (2) the related auditor's report is no longer
                        reliable.

           This includes communication (1) in writing to the Congress, OMB,
           Treasury, and GAO; (2) to the public on the Internet pages where
           the agency's previously issued financial statements that were
           affected by the material misstatement(s) or potential material
           misstatement(s) are published; and (3) to OMB in the agency's next
           quarterly financial statements and in subsequent quarterly
           financial statements until the specific amount(s) of the material
           misstatement(s) and the related effect(s) of such on the
           previously issued financial statement(s) are known and reported.

           GAO also recommends that the following requirements be added to
           section 5 of OMB Bulletin No. 06-03, Audit Requirements for
           Federal Financial Statements, as follows:

           5.3 The auditor shall review the adequacy of management's
           communication information about the known or potential material
           misstatement(s) to report users, including those charged with
           governance, oversight bodies, and funding agencies. When
           performing this review, the auditor shall consider whether (1)
           management acted timely to determine the financial statement
           effects of the potential material misstatement(s), (2) management
           acted timely to communicate with appropriate parties, and (3)
           management disclosed the nature and extent of the known or likely
           material misstatement(s) on Internet pages where the agency's
           previously issued financial statements are published.

           5.4 The auditor shall notify those charged with governance if the
           auditor believes that management is unduly delaying its
           determination of the effect(s) of the misstatement(s) on a
           previously issued financial statement(s).

           5.5 The auditor shall evaluate the timeliness and appropriateness
           of management's decision whether to issue restated financial
           statement(s). Management may separately issue the restated
           financial statement(s) or may present the restated financial
           statement(s) on a comparative basis with those of a subsequent
           period. Ordinarily, the auditor would expect management to issue
           restated financial statement(s) as soon as practicable. However,
           it may not be necessary for management to separately issue the
           restated financial statement(s) and the auditor's report when
           issuance of the subsequent period audited financial statements is
           imminent.3

           5.6 If the auditor becomes aware of a material misstatement(s) or
           potential misstatement(s) affecting a previously issued financial
           statement(s), then the auditor shall advise the agency's
           management to determine the specific amount(s) of the material
           misstatement(s) or potential material misstatement(s) and the
           related effect(s) of such on the previously issued financial
           statement(s) as soon as reasonably possible.

           5.7 If the specific amount(s) of the material misstatement(s) and
           the related effect(s) of such on a previously issued financial
           statement(s) are known and the issuance of the subsequent period
           audited financial statements is not imminent, then the auditor
           shall advise the agency's management to promptly:

                        o  reissue the most recently issued fiscal year
                        financial statements before issuing the current
                        fiscal year's financial statements;

                        o  communicate the reissuance to those charged with
                        governance, oversight bodies, funding agencies, and
                        others who are relying or are likely to rely on the
                        financial statement(s). This includes communication
                        (1) in writing to the Congress, OMB, Treasury, and
                        GAO and (2) to the public on the Internet pages where
                        the agency's previously issued financial statements
                        that were affected by the material misstatement(s)
                        are published; and

                        o  disclose the following information, at a minimum,
                        in the agency's restatement footnotes: (1) the nature
                        and cause(s) of the misstatement(s) that led to the
                        need for restatement, and (2) the specific amount(s)
                        of the material misstatement(s) and the related
                        effect(s) on the previously issued financial
                        statement(s) (e.g., year(s) being restated, specific
                        financial statement(s) affected and line items
                        restated, actions the agency's management took after
                        discovering the misstatement), and the impact on the
                        financial statements as a whole (e.g., change in
                        overall net position, change in the audit opinion).

           5.8 If the specific amount(s) of the material misstatement(s) and
           the related effect(s) of such on a previously issued financial
           statement(s) are known and issuance of the subsequent period
           audited financial statements is imminent, then the auditor shall
           disclose restatements in the auditor's report as listed in 7.7 and
           advise agency's management to:

                        o  issue restated financial statement(s) as part of
                        the current year's comparative financial statements;

                        o  communicate the restatement to those charged with
                        governance, oversight bodies, funding agencies, and
                        others who are relying or are likely to rely on the
                        financial statement(s). This includes communication
                        (a) in writing to the Congress, OMB, Treasury, and
                        GAO and (b) to the public on the Internet pages where
                        the agency's previously issued financial statements
                        that were affected by the material misstatement(s)
                        are published; and

                        o  disclose the following information, at a minimum,
                        in the agency's restatement footnote: (1) the nature
                        and cause(s) of the misstatement(s) that led to the
                        need for restatement and (2) the specific amount(s)
                        of the material misstatement(s) and the related
                        effect(s) on the previously issued financial
                        statement(s) (e.g., year(s) being restated, specific
                        financial statement(s) affected and line items
                        restated, actions the agency's management took after
                        discovering the misstatement), and the impact on the
                        financial statements as a whole (e.g., change in
                        overall net position, change in the audit opinion).

           5.9 If the specific amount(s) of the misstatement(s) and the
           related effect(s) of such on a previously issued financial
           statement(s) remain unknown when the current year's financial
           statements are issued, then the auditor shall follow 7.8 when
           issuing the auditor's report and advise the agency's management as
           required in 5.2.

           5.10 The auditor shall notify those charged with governance,
           oversight bodies, and funding agencies when management (1) does
           not take the necessary steps to promptly inform report users of
           the situation or (2) does not restate with appropriate timeliness
           the financial statements in circumstances when the auditor
           believes they need to be restated. The auditor shall inform these
           parties that the auditor will take steps to prevent future
           reliance on the auditor's report. The steps taken will depend on
           the facts and circumstances, including legal considerations. This
           includes communication in writing to the Congress, OMB, Treasury,
           and GAO as well as any other users known to be relying on the
           previously issued financial statement(s).

           GAO recommends that section 7.7 of OMB Bulletin No. 06-03, Audit
           Requirements for Federal Financial Statements, be modified to read
           as follows:

           7.7 When management restates a previously issued financial
           statement(s), the auditor shall perform audit procedures
           sufficient to reissue or update the auditor's report on the
           restated financial statement(s). The auditor shall fulfill these
           responsibilities whether the restated financial statement(s) are
           separately issued or presented on a comparative basis with those
           of a subsequent period. The auditor shall include the following
           information in an explanatory paragraph in the reissued or updated
           auditor's report on the restated financial statement(s):

                        o  a statement disclosing that a previously issued
                        financial statement(s) has been restated,

                        o  a statement that the previously issued financial
                        statement(s) was materially misstated and that the
                        previously issued auditor's report (including report
                        date) is withdrawn and replaced by the auditor's
                        report on the restated financial statement(s),

                        o  a reference to the note(s) to the restated
                        financial statement(s) that discusses the
                        restatement,

                        o  a description of the following if not already
                        provided in the note(s) to the financial
                        statement(s): (1) the nature and cause(s) of the
                        misstatement(s) that led to the need for restatement
                        and (2) the specific amount(s) of the material
                        misstatement(s) and the related effect(s) on the
                        previously issued financial statement(s) (e.g.,
                        year(s) being restated and the specific financial
                        statement(s) affected and line items restated) and
                        the impact on the financial statements as a whole
                        (e.g., change in overall net position, change in the
                        audit opinion), and

                        o  a discussion of any significant internal control
                        deficiency that failed to prevent or detect the
                        misstatement and what action management has taken
                        about the deficiency.

           GAO also recommends that the following requirements be added to
           section 7 of OMB Bulletin No. 06-03, Audit Requirements for
           Federal Financial Statements, as follows:

           7.8 If at the time of issuance of the auditor's report a material
           misstatement(s) or potential material misstatement(s) has been
           identified in any of the previously issued financial statements
           and the specific amount(s) of the misstatement(s) and the related
           effect(s) of such are not known, then the auditor shall update the
           auditor's report on the previously issued financial statement(s)
           as appropriate. Furthermore, the auditor's report shall disclose,
           at a minimum, the following:
			  			  
                        o  a statement disclosing that a material
                        misstatement(s) or potential material misstatement(s)
                        affects a previously issued financial statement(s)
                        but the specific amount(s) of the misstatement(s) and
                        the related effect(s) of such are not known;

                        o  a reference to note(s) to the financial statements
                        that discusses the restatement or potential
                        restatement;

                        o  a description of the following, if not already
                        provided in the agency's note(s) to the financial
                        statements: (1) the nature and cause(s) of the
                        misstatement(s) or potential misstatement(s), and (2)
                        an estimate of the magnitude of the misstatement(s)
                        or potential misstatement(s) and the related
                        effect(s) of such on a previously issued financial
                        statement(s) (e.g., disclosure of the specific
                        financial statement(s) and line items affected) that
                        are known and a statement that the specific amount(s)
                        and the related effect(s) of such cannot be
                        determined without further investigation; and

                        o  a statement disclosing that a restatement(s) to a
                        previously issued financial statement(s) will or may
                        occur.

           Appendix II: GAO Contact and Staff Acknowledgments
			  
			  GAO Contact
			  
			  Gary T. Engel, (202) 512-3406.

           Acknowledgments
			  
			  Arthur W. Brouk, Alberto Garza, Michael D. Hansen, Malissa
           Livingston, and Michelle Philpott made key contributions to this
           report.

           Related GAO Products
			  
			  Fiscal Year 2004 U.S. Government Financial Statements: Sustained
           Improvement in Federal Financial Management Is Crucial to
           Addressing Our Nation's Future Fiscal Challenges. GAO-05-284T .
           Washington, D.C.: February 9, 2005.

           Financial Audit: Restatements to the Department of State's Fiscal
           Year 2003 Financial Statements. GAO-05-814R . Washington, D.C.:
           September 20, 2005.

           Financial Audit: Restatements to the Nuclear Regulatory
           Commission's Fiscal Year 2003 Financial Statements. GAO-06-30R .
           Washington, D.C.: October 27, 2005.

           Financial Audit: Restatement to the General Services
           Administration's Fiscal Year 2003 Financial Statements. GAO-06-70R
           . Washington, D.C.: December 6, 2005.

           Financial Audit: Restatements to the National Science Foundation's
           Fiscal Year 2003 Financial Statements. GAO-06-229R . Washington,
           D.C.: December 22, 2005.

           Financial Audit: Restatements to the Department of Agriculture's
           Fiscal Year 2003 Consolidated Financial Statements. GAO-06-254R .
           Washington, D.C.: January 26, 2006.

           Fiscal Year 2005 U.S. Government Financial Statements: Sustained
           Improvement in Federal Financial Management is Crucial to
           Addressing Our Nation's Financial Condition and Long-term Fiscal
           Imbalance. GAO-06-406T . Washington, D.C.: March 1, 2006.

           Related GAO Products
			  
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10Our review did not include 2 of the 11 agencies that had restatements
for fiscal year 2003 because these agencies did not receive unqualified
opinions on their originally issued fiscal year 2003 financial statements.
Reports were issued to the Department of Agriculture, Department of State,
General Services Administration, National Science Foundation, and Nuclear
Regulatory Commission. We did not issue separate reports dealing with the
other 4 agencies (Departments of Justice, Transportation, and Health and
Human Services, and the Office of Personnel Management) since those
agencies' restatements primarily dealt with material misstatements
affecting the Statement of Budgetary Resources, which we have already
reported on in our February 2005 and March 2006 testimonies. See our
Related GAO Products page for a list of these reports as well as other
related GAO products.

11According to Federal Accounting Standards Advisory Board, Statement of
Federal Financial Accounting Concepts No. 2, Entity and Display, financial
information is also conveyed with accompanying footnotes, which are an
integral part of the financial statements. Footnotes typically provide
additional disclosures that are necessary to make the financial statements
more informative and not misleading.

12According to American Institute of Certified Public Accountants,
Codification of Auditing Standards, AU section 561, Subsequent Discovery
of Facts Existing at the Date of the Auditor's Report (1972), when the
auditor has concluded that subsequently discovered information would have
affected the previously issued audit report and believes there are persons
relying or likely to rely on the previously issued financial statements,
the auditor should take action to prevent future reliance on the
previously issued audit report. To appropriately withdraw the previously
issued audit report, the auditor may reissue the audit report separately
from the audit report on the current-period financial statements or issue
an updated report in conjunction with the audit report on the
current-period financial statements as discussed in American Institute of
Certified Public Accountants, Codification of Auditing Standards, AU
section 508, Reports on Audited Financial Statements (1989).

13According to Federal Accounting Standards Advisory Board, Statement of
Federal Financial Accounting Concepts No. 1, Objectives of Federal
Financial Reporting, financial reports must be understandable, reliable,
relevant, timely, consistent, and comparable.

14Office of Management and Budget, Circular No. A-136 Revised, Financial
Reporting Requirements, August 23, 2005.

15OMB revised Circular No. A-136 again on July 24, 2006; however, there
were minimal changes to guidance related to restatements.

16As noted previously, OMB issued guidance to agency management and agency
auditors on July 24, 2006 and August 23, 2006, respectively.

17At least 7 of the 24 CFO Act agencies restated certain of their fiscal
year 2004 financial statements to correct misstatements. Three of these
agencies had received an unqualified opinion on their originally issued
fiscal year 2004 financial statements while the remaining 4 had received a
disclaimer of opinion on their financial statements. The auditor for one
of the agencies withdrew the unqualified opinion that had been previously
rendered on the agency's fiscal year 2004 financial statements and issued
a qualified opinion on the restated financial statements.

18OMB Circular No. A-136 was revised during fiscal years 2005 and 2006 and
supersedes OMB Bulletin No. 01-09.

19According to Federal Accounting Standards Advisory Board, Statement of
Federal Financial Accounting Standards No. 21, Reporting Corrections of
Errors and Changes in Accounting Principles, a prior period adjustment is
defined as a correction for an error that occurred in and whose cumulative
effect is attributable to periods not presented in the current financial
statements.

20According to American Institute of Certified Public Accountants,
Codification of Auditing Standards, AU section 420, Consistency of
Application of Generally Accepted Accounting Principles (1972),
classifications in the current financial statements may be different from
classifications in the prior year's financial statements. Although changes
in classification are usually not of sufficient importance to necessitate
disclosure, material changes in classification should be indicated and
explained in the financial statements or notes.

21Specifically, two audit reports neither disclosed the restatement nor
referred to the restatement footnote and another audit report disclosed

22Subsequent to our initial review, OMB issued OMB Bulletin No. 06-03,
Audit Requirements for Federal Financial Statements on August 23, 2006,
which now supersedes OMB Bulletin No. 01-02. OMB Bulletin No. 06-03
provides a definition for what is considered "imminent." Specifically, OMB
defines imminent as being "within 90 calendar days of the subsequent
period financial statements planned issue date."

23The auditor did not provide us with documentation of the basis for its
conclusion that users were not likely to still be relying on fiscal year
2003 financial statements and would not attach importance to the
correction of the material error.

24As noted previously, OMB issued guidance to agency management and agency
auditors on July 24, 2006 and August 23, 2006, respectively.

1Financial statements are restated to correct an error(s) in previously
issued financial statement(s).

2For purposes of this guidance, imminent means within 90 days of
determining the effect of the misstatement(s) on the previously issued
financial statements.

3For purposes of this guidance, imminent means within 90 days of
determining the effect of the misstatement(s) on the previously issued
financial statements.

(198416)

www.gao.gov/cgi-bin/getrpt? GAO-07-91 .

To view the full product, including the scope
and methodology, click on the link above.

For more information, contact Gary T. Engel at (202) 512-3406 or
[email protected].

Highlights of GAO-07-91 , a report to the Director of the Office of
Management and Budget

October 2006

FINANCIAL AUDIT

Restated Financial Statements: Agencies' Management and Auditor
Disclosures of Causes and Effects and Timely Communication to Users

GAO continues to have concerns about restatements to federal agencies'
previously issued financial statements. During fiscal year 2005, at least
7 of the 24 Chief Financial Officers (CFO) Act agencies restated certain
of their fiscal year 2004 financial statements to correct misstatements.
To study this trend, GAO reviewed the nature and causes of the
restatements made by certain CFO Act agencies in fiscal year 2004 to their
fiscal year 2003 financial statements. Eleven CFO Act agencies had
restatements for fiscal year 2003. Nine of those 11 received unqualified
opinions on their originally issued fiscal year 2003 financial statements.
GAO's view is that users of federal agencies' financial statements and the
related audit reports need to be provided at least a basic understanding
of why a restatement was necessary and its effect on the agencies'
previously issued financial statements and related audit reports. This
report communicates GAO's observations on the transparency and timeliness
of the 9 federal agencies' and their auditors' restatement disclosures.

What GAO Recommends

GAO is making 11 recommendations to the Office of Management and Budget
(OMB) to further improve the restatement guidance available to agencies'
management and the agencies' respective auditors. OMB stated that it would
take GAO's recommendations under advisement. GAO reiterates its concern
that it is critical for OMB to timely provide additional restatement
guidance.

The nine agencies GAO reviewed did not consistently communicate financial
statement restatements. GAO found that all nine agencies could have
greatly enhanced the adequacy, effectiveness, and timeliness of their
restatement disclosures to users. Similar transparency issues existed with
the associated audit reports regarding disclosure of all the essential
information that would clearly explain the restatements. GAO highlighted
the following issues as among the more prevalent issues to be addressed:

           o  columns of the agencies' restated financial statements were not
           labeled as "Restated,"
           o  agencies' restatement footnote disclosures lacked clarity or
           sufficient detail regarding the nature of the restatements and the
           effect on balances reported in previously issued financial
           statements,
           o  restatement information was not sufficiently disclosed in the
           agencies' Management Discussion and Analysis,
           o  audit reports did not disclose that the respective agencies had
           restated certain of their fiscal year 2003 financial statements,
           o  audit reports did not provide a statement that the previously
           issued audit report was withdrawn and replaced by the opinion on
           the restated financial statements, and
           o  material misstatements and potential material misstatements
           were not timely communicated by agencies to either their auditors
           or to the users of the financial statements.

The primary contributing factor for the restatement disclosure issues that
GAO identified was insufficient guidance available at the time to both the
agencies' management and their respective auditors for disclosure of the
restatements and the timeliness of such disclosures. GAO believes that
information regarding restatements should be disclosed in a transparent
and timely manner consistent with the qualitative characteristics of
information in financial reports described in Statement of Federal
Financial Accounting Concepts (SFFAC) No. 1. In GAO's view, more detailed
accounting and auditing guidance on how to satisfy the financial reporting
characteristics as outlined in SFFAC No. 1 as it relates to the disclosure
of restatements would have been helpful. OMB revised Circular No. A-136,
Financial Reporting Requirements, which provides additional guidance to
federal agencies' management regarding disclosure of restatements to
previously issued financial statements. Revisions made to OMB Circular No.
A-136 address many of GAO's concerns regarding the agencies' disclosure of
restatements. In addition, the proposed 2006 revision of generally
accepted government auditing standards now includes a section on reporting
on restatement of previously issued financial statements. In addition, on
August 23, 2006, OMB issued Bulletin No. 06-03, which also provides some
information regarding reporting on restatements. However, GAO believes
that OMB needs to timely provide additional, though complementary,
restatement guidance to both the agencies' management and their respective
auditors.
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