Financial Management: Fostering the Effective Implementation of
Legislative Goals (Testimony, 06/18/1998, GAO/T-AIMD-98-215).
Financial management reform legislation, such as the 1990 Chief
Financial Officers Act and the 1996 Federal Financial Management
Improvement Act, have established a broad-based set of expectations for
improving financial management in the government, including producing
reliable financial reports, generating sound cost and performance
information, fixing weaknesses in systems and controls, and building
effective financial management organizations. This testimony discusses
ways that Congress can help ensure that federal agencies effectively
implement such laws.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-AIMD-98-215
TITLE: Financial Management: Fostering the Effective
Implementation of Legislative Goals
DATE: 06/18/1998
SUBJECT: Accounting procedures
Federal agency accounting systems
Financial management systems
Financial statement audits
Government liability (legal)
Internal controls
Congressional oversight
Reporting requirements
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GAO/T-AIMD-98-215
Cover
================================================================ COVER
Before the Subcommittee on Government Management, Information and
Technology, Committee on Government Reform and Oversight, House of
Representatives
For Release on Delivery
Expected at
9:30 a.m.
Thursday,
June 18, 1998
FINANCIAL MANAGEMENT - FOSTERING
THE EFFECTIVE IMPLEMENTATION OF
LEGISLATIVE GOALS
Statement of Gene L. Dodaro
Assistant Comptroller General
Accounting and Information Management Division
GAO/T-AIMD-98-215
GAO/AIMD-98-215t
(919285)
Abbreviations
=============================================================== ABBREV
CFO -
DOD -
FASAB -
FFMIA -
IRS -
OMB -
SFFAC -
SFFAS -
SSA -
============================================================ Chapter 0
Mr. Chairman and Members of the Subcommittee:
We are pleased to discuss ways the Congress can help ensure that
agencies effectively implement federal financial management reform
legislation. This legislative framework includes the 1990 Chief
Financial Officers (CFO) Act, as expanded by the 1994 Government
Management Reform Act, as well as the 1996 Federal Financial
Management Improvement Act (FFMIA). These statutes establish a
broad-based set of expectations for improving financial management,
such as producing reliable financial reports, generating sound cost
and performance information, fixing weaknesses in systems and
controls, and building effective financial management organizations.
An essential foundation to help achieve these goals is the
requirement that the 24 CFO Act agencies annually prepare financial
statements and subject them to an independent audit, beginning with
those for fiscal year 1996. Additionally, audited consolidated
financial statements for the U.S. government are now required
annually, starting with those for fiscal year 1997. To further
promote needed reforms, FFMIA calls for agencies to meet various
financial management standards and requirements and, if they do not,
to prepare remediation plans.
These reforms begin to subject the federal government to the same
fiscal discipline imposed for years on the private sector and state
and local governments. This discipline is needed to correct
long-standing serious weaknesses in federal financial management
systems, controls, and reporting practices. Considerable effort is
underway across government to make needed improvements and progress
is being made, but a great deal of perseverance will be required to
fully attain the legislative goals set by federal financial
management statutes.
To build upon these efforts, the Subcommittee is exploring ways to
expedite fixing the problems that hamper effective financial
management across government today. The Subcommittee's efforts are
in concert with the House of Representatives resolution (H.Res.
447), passed on June 9, 1998, which underscored congressional demands
for quickly resolving outstanding financial management problems.
The federal government can continue to make progress in implementing
financial management reforms, but the pace and extent of improvement
will depend upon the dedication of agency heads and their senior
management teams, especially the Chief Financial Officers, and the
ability to deal with a range of financial management systems issues,
as well as continuing emphasis by the Congress on financial
management reform. Broad oversight by the Congress will be very
important to holding agency heads accountable for needed financial
management improvements. The Congress would make a significant
contribution to ensuring satisfactory results in this area if the
results of financial audits and needed improvements became a routine
part of its normal annual appropriation, authorization, and oversight
deliberations.
PROGRESS IS BEING MADE
---------------------------------------------------------- Chapter 0:1
Since the CFO Act's passage, steady progress has been made in
improving federal financial management. A set of comprehensive
accounting standards has been completed by the Federal Accounting
Standards Advisory Board (FASAB), agencies are progressing in
receiving unqualified audit opinions on financial statements, and
structures are in place to identify and resolve governmentwide
financial management issues.
FASAB was created by the Secretary of the Treasury, the Director of
Office of Management and Budget (OMB), and the Comptroller General in
October 1990 to consider and recommend federal accounting standards.
Treasury, OMB, and GAO then decide whether to adopt the recommended
standards; if they do, the standards are published by OMB and GAO and
become effective. Statements of federal financial accounting
concepts and standards, which are listed in attachment I, now provide
for reporting on the federal government's financial condition, as
well as on the costs of its programs.
For fiscal year 1996, when agencywide financial statements were
required across government for the first time, 6 of the 24 CFO Act
agencies received unqualified audit opinions. For the next year,
fiscal year 1997, 9 agencies received unqualified audit opinions, and
OMB expects an additional agency to receive an unqualified opinion by
the end of June 1998.\1 The preparation of financial statements and
independent audit opinions required by the expanded CFO Act are
bringing greater clarity and understanding to the scope and depth of
problems and needed solutions.
Some individual agencies have successfully solved these problems.
For example, the Social Security Administration (SSA) prepared
financial statements for fiscal year 1987--prior to the expanded CFO
Act's requirement--addressed financial weaknesses, and attained its
first unqualified audit opinion for fiscal year 1994. As this
Subcommittee heard at its April 17, 1998, hearing, SSA now produces
financial statements within 2 months of the close of the fiscal year
and continues to receive unqualified audit opinions annually.
At the Department of Energy, the Inspector General identified
problems related to the balance sheet Energy prepared for fiscal year
1995. The problems, for example, involved identifying liabilities
associated with environmental cleanup and controls over property and
equipment, which Energy worked to correct. The following year,
fiscal year 1996, Energy prepared agencywide financial statements
that received an unqualified opinion and sustained these results for
fiscal year 1997.
Many people are actively working to resolve federal financial
management problems. For example, OMB has issued guidance to
agencies on producing useful financial reports that meet FASAB
standards. In addition to individual CFOs working to address issues
in their agencies, the CFO Council, working with OMB, develops an
annual financial management status report and 5-year plan.
Inspectors General are carrying out their responsibilities to ensure
annual audits of financial statements.
--------------------
\1 These agencies are the Social Security Administration, the
National Aeronautics and Space Administration, the Nuclear Regulatory
Commission, the Department of Energy, the General Services
Administration, the Department of Labor, the Small Business
Administration, the Environmental Protection Agency, and the
Department of the Interior. OMB expects the Department of Education
to receive an unqualified opinion by June 30, 1998.
REACTION TO THE FIRST
GOVERNMENTWIDE FINANCIAL
STATEMENT AUDIT RESULTS
---------------------------------------------------------- Chapter 0:2
On March 31, 1998, the Secretary of the Treasury, in consultation
with the Director of OMB, issued the 1997 Consolidated Financial
Statements of the United States Government. These audited
governmentwide financial statements were the first prepared and
issued under provisions of the expanded CFO Act and included our
first report required by the act.\2
On April 1, 1998, we testified\3 before this Subcommittee on the
results of our audit. Our testimony framed the most serious
financial management improvement challenges facing the federal
government. In summary, significant financial systems weaknesses;
problems with fundamental recordkeeping; incomplete documentation;
and weak internal controls, including computer controls, prevented
the government from accurately reporting a large portion of its
assets, liabilities, and costs. Our audit of the federal
government's consolidated financial statements and the Inspectors
General audits of agencies' financial statements have resulted in an
identification and analysis of deficiencies in the government's
recordkeeping and control system and recommendations to correct them.
The executive branch recognizes the extent and severity of the
financial management deficiencies and that addressing them will
require concerted improvement efforts across government. Financial
management has been designated one of the President's priority
management objectives, with the goal of having performance and cost
information in a timely, informative, and accurate way, consistent
with federal accounting standards. Also, the administration has set
goals for individual agencies, as well as the government as a whole,
to complete audits and gain unqualified opinions.
To help achieve these objectives, the President issued a May 26,
1998, memorandum to the heads of executive departments and agencies
on actions needed to improve financial management. The President's
message points to several areas requiring agencies additional
attention: practices related to the government's property, federal
credit programs, liabilities related to the disposal of hazardous
waste and remediation of environmental contamination, federal
government employment-related benefits liabilities, and transactions
between federal entities. These areas reflect the serious
deficiencies that prevented us from being able to form an opinion on
the reliability of the consolidated financial statements of the U.S.
government.
The President's directive places additional accountability on agency
heads and gives OMB more responsibility for addressing these
problems. Specifically, he has directed that:
-- OMB identify agencies subject to reporting under the President's
memorandum and monitor their progress towards the goal of having
an unqualified audit opinion on the governmentwide financial
statements for fiscal year 1999.
-- The head of each agency identified by OMB submit to OMB a plan,
including milestones, for resolving by September 30, 1999,
financial reporting deficiencies identified by auditors. The
initial agency plans are due to OMB by July 31, 1998.
-- The head of each agency submitting a plan provide quarterly
reports to OMB, starting on September 30, 1998, describing
progress in meeting the milestones in their action plan and any
impediments that would impact the governmentwide goal.
-- OMB provide periodic reports to the Vice President on the agency
submissions and governmentwide actions taken to meet the
governmentwide goal.
Specific agencies, such as the Department of Defense (DOD), are also
reacting to the results of the most recent financial audits. As we
testified before this Subcommittee on April 16, 1998, material
financial management deficiencies identified at DOD, taken together,
represent the single largest obstacle that must be effectively
addressed to achieve an unqualified opinion on the U.S. government's
consolidated financial statements.\4 In response to DOD's unfavorable
financial audit results over the last several years, the Secretary of
Defense announced on May 15, 1998, that initiatives to improve the
accuracy, timeliness, and usefulness of financial information are to
be developed through the Defense Management Council. The Secretary
has (1) instructed the Under Secretary (Comptroller) to oversee
departmentwide efforts to improve the manner in which financial
information is captured and reported in all DOD systems--not just its
financial systems--and (2) directed the secretaries of the military
departments, and other top DOD officials, to support the Under
Secretary (Comptroller) in DOD's financial business practices reform.
Reactions such as these to address the problems identified through
the first audit of the U.S. government's consolidated financial
statements are positive steps. In the short term, the quality of the
action plans agency heads submit to OMB in response to the
President's directive will be critical. It is essential for these
plans to define financial management problems precisely, establish
specific strategies and corrective measures for resolving them,
include implementation time frames, fix accountability for needed
actions, and be prepared in consultation with auditors. Moreover,
our experience has shown that considerable hard work, commitment, and
oversight will be necessary to translate planned steps into concrete
improvements.
The aggressiveness with which agencies implement the action plans and
pursue solutions to financial management problems will be a strong
indication of whether agency heads have a sustained commitment to
achieving financial management reform goals. Ultimately, agency
heads and their senior management team have to be accountable for
results. Again, the auditors have key roles in providing
perspectives on actions needed to attain improvements and in
assessing progress toward implementing the action plans.
--------------------
\2 Financial Audit: 1997 Consolidated Financial Statements of the
United States Government (GAO/AIMD-98-127, March 31, 1998).
\3 U.S. Government Financial Statements: Results of GAO's Fiscal
Year 1997 Audit (GAO/T-AIMD-98-128, April 1, 1998).
\4 Department of Defense: Financial Audits Highlight Continuing
Challenges to Correct Serious Financial Management Problems
(GAO/T-AIMD/NSIAD-98-158, April 16, 1998).
YEAR 2000 COMPUTING CRISIS AND
MODERNIZING FINANCIAL SYSTEMS
---------------------------------------------------------- Chapter 0:3
Federal agencies will have great difficulty meeting expectations for
modernizing their financial management systems unless they
effectively meet the Year 2000 computing challenge.\5 As we have
discussed in numerous testimonies before this Subcommittee, this
issue is the most sweeping and urgent information technology
challenge facing organizations today. Strong leadership is needed to
avoid major disruptions in services and financial operations, such as
processing financial transactions, reporting financial information,
controlling property, and collecting revenue.
Unless this issue is successfully addressed, serious consequences
could occur. For example:
-- payments to veterans with service-connected disabilities could
be severely delayed if the system that issues them either halts
or produces checks so erroneous that it must be shut down and
checks processed manually;
-- the SSA process to provide benefits to disabled persons could be
disrupted if interfaces with state systems fail;
-- federal systems used to track student loans could produce
erroneous information on loan status, such as indicating that a
paid loan was in default;
-- IRS tax systems could be unable to process returns, thereby
jeopardizing revenue collection and delaying refunds; and
-- the military services could find it extremely difficult to
efficiently and effectively equip and sustain U.S. forces
around the world.
This Subcommittee's emphasis has helped to focus on the potential
consequences of the Year 2000 computing crisis and the need for added
impetus by some agencies to overcome vast difficulties within the
next 18 months. In our most recent testimony before the Subcommittee
on June 10, 1998, we reported that progress in addressing Year 2000
continues at a slow pace, and that as the amount of time to the turn
of the century shortens, the magnitude of what must be accomplished
becomes more daunting.\6 We have issued over 40 reports and testimony
statements detailing specific findings and recommendations related to
the Year 2000 readiness of a wide range of federal agencies.
Moreover, to reduce the risk of widespread disruptions, we have made
several governmentwide recommendations to the President's Council on
Year 2000 Conversion and OMB to expedite the efforts of federal
agencies and build strong partnerships with the private sector and
state and local governments.
This will likely affect the pace of progress on modernizing financial
systems, as some agencies' efforts to address the Year 2000 computing
crisis are taking precedence over longer-term financial management
systems development and improvement initiatives. Unless successfully
dealt with, this crisis presents the likelihood of new financial
management systems weaknesses occurring, existing problems worsening,
and ongoing reform efforts being derailed.
--------------------
\5 For the past several decades, information systems have typically
used two digits to represent the year, such as "98" for 1998, in
order to conserve electronic data storage and reduce operating costs.
In this format, however, 2000 is indistinguishable from 1900 because
both are represented as "00." As a result, if not modified, computer
systems or applications that use dates or perform date- or
time-sensitive calculations may generate incorrect results beyond
1999.
\6 Year 2000 Computing Crisis: Actions Must Be Taken Now to Address
Slow Pace of Federal Progress (GAO/T-AIMD-98-205, June 10, 1998).
CONGRESSIONAL OVERSIGHT IS KEY
---------------------------------------------------------- Chapter 0:4
Congressional attention is essential to help sustain the current
momentum to implement financial management reform legislation. There
are clear indications that the results of financial audits are
beginning to attract increasing attention from various congressional
committees.
One instance involves the audit of IRS's financial statements.
During our first audits, beginning with fiscal year 1992, we
identified serious problems and were unable to give an opinion on
IRS's financial statements. The head of IRS was called before
congressional committees in both the House and Senate on numerous
occasions to explain the steps IRS was taking, and the progress it
was making, to overcome them. On April 15, 1998, we testified\7
before this Subcommittee that after several years of concerted effort
by IRS and GAO, we were, for the first time, able to conclude that
IRS's custodial financial statements were reliable.\8 These positive
results show that focused attention by the Congress and this
Subcommittee on IRS's financial management has begun to improve
information available to IRS management and to the Congress to help
make decisions.
In addition, issues raised by financial audits are beginning to
prompt inquiries among various congressional committees, as
exemplified by the following.
-- In its reports for the fiscal years 1997 and 1998 appropriations
bills, the Subcommittee on Labor, Health and Human Services,
Education and Related Agencies of the House Committee on
Appropriations (1) set the expectation that the Departments of
Labor, Health and Human Services, and Education work vigorously
toward obtaining clean audit opinions, (2) questioned whether
these agencies could properly exercise the substantial transfer
and reprogramming authority granted to them under the
appropriations act if substantial financial management reform
progress had not been made, and (3) stated that in subsequent
years it would consider the agencies' progress in making such
reforms and obtaining clean financial statement audit opinions
when scrutinizing requests for appropriations and in deciding
whether to continue, expand, or limit transfer and reprogramming
authority.
-- The Chairman of the House Committee on the Budget asked us to
monitor the Forest Service's progress in improving the
reliability of its accounting and financial data, which also
contributed to a recent joint hearing before the House Committee
on Resources, Committee on the Budget, and Subcommittee on
Interior and Related Agencies, Committee on Appropriations,
focusing on inefficiency and waste resulting from the Forest
Service's lack of financial and performance accountability.\9
-- After considering funding for DOD for fiscal year 1998, the
Senate Armed Services Committee legislatively required DOD to
prepare biennial financial management improvement plans that
include a concept of operations for the financial management of
the department.\10 The first such plan is to be submitted to the
Congress by September 30, 1998. In approving DOD's 1997 and
1998 appropriations, the Congress also put in place a
legislative requirement to accelerate DOD's planned timetable
for addressing long-standing problems in accurately and promptly
accounting for billions of dollars in disbursements.\11
Additionally, as part of DOD's 1999 authorization, the Senate
Armed Services Committee has approved a requirement for DOD to
provide a detailed annual report on the quantities and locations
of DOD's multibillion dollar investment in inventories and
military equipment.
-- The Chairman of the House Budget Committee asked us to analyze
the programmatic and budgetary implications of the financial
data deficiencies enumerated by the auditors' examination of the
Department of the Navy's fiscal year 1996 financial statements.
In March 1998, we advised the Chairman that the extent and
nature of the Navy's financial deficiencies identified by the
auditors, including those that relate to supporting management
systems, increases the risk of waste, fraud, and
misappropriation of Navy funds and can drain resources needed
for defense mission priorities.\12
-- On April 24, 1998, this Subcommittee and the House Committee on
Commerce's Subcommittees on Oversight and Investigations, Health
and Environment held a joint hearing on the Department of Health
and Human Service Inspector General's audit of the Health Care
Financing Administration's fiscal year 1997 financial
statements. This helped focus attention on fixing the control
weaknesses associated with the more than $20 billion of improper
payments in the Medicare fee-for-service program disclosed by
the financial audit.
-- In February 1998, we assisted the Chairman of the House
Committee on the Budget in considering the possible program and
budgetary implications of the questions raised about financial
statement data deficiencies identified in the Department of
Transportation Inspector General's audit report on the Federal
Aviation Administration's fiscal year 1996 Statement of
Financial Position.\13
In addition to initiatives by individual congressional committees,
the Federal Financial Management Improvement Act provides the
Congress another tool in monitoring the progress of all 24 CFO Act
agencies in improving financial systems. The act is intended to
increase accountability in federal financial management and develop
systems with the capability to support FASAB standards. FFMIA also
provides for an independent judgment by auditors of agencies' efforts
to foster compliance with financial management improvement goals.
Under the act, agencies are required to comply with federal
accounting standards, federal financial systems requirements, and the
U.S. government's standard general ledger at the transaction level.
This legislation also requires (1) auditors performing financial
audits under the CFO Act to report whether agencies comply with these
requirements and (2) if agencies do not comply, agency heads are to
prepare remediation plans to bring financial management systems into
substantial compliance within 3 years.
We reported in October 1997\14 that prior audit results and agency
self-reporting all point to significant challenges that agencies must
meet to fully implement these requirements. The majority of federal
agencies' financial management systems are not designed to meet
current accounting standards and systems requirements and cannot
provide reliable financial information for managing government
operations and holding managers accountable. Auditors' reports for
fiscal year 1997 agency financial audits are disclosing the
continuing poor shape in which agencies find their financial systems.
To date, the financial systems of only four agencies are reported to
be in substantial compliance with the requirements and standards
FFMIA specifies.\15
The Congress can build further upon this structure by conducting
annual hearings on each agency as part of the regular appropriation,
authorization, and oversight process. Each year, congressional
committees could review the results of agencies' most recent
financial statement audits and FFMIA reports to gauge the progress
agencies are making in improving financial management. Agency heads
could be required to describe remedial actions being taken to address
financial management problems identified by independent auditors.
Through this process, the Congress can, therefore, be in an informed
position to assess progress in achieving legislative financial
management improvement reforms, addressing the Year 2000 computing
crisis, and meeting the President's financial statement audit goals.
This would allow thorough consideration of the severity of an
agency's financial management problems, the demonstrated commitment
to improvement efforts, and the independent perspectives of the
auditors on an agency's progress in responding to financial statement
audit recommendations. Using the results of this assessment, the
Congress can clearly determine accountability and tailor needed
additional actions.
Based on the circumstances of individual agencies on a case-by-case
basis, the Congress could, for example, consider whether (1) in areas
of special concern, to require attainment of specified improvements
within established milestones before certain funds supporting
administrative operations or systems would be available for
obligation, (2) to expand, continue, or limit transfer or
reprogramming authority depending on the quality of an agency's
financial management, (3) to target, or set aside, needed funding for
financial management improvement efforts that are deemed necessary to
achieve progress and require periodic status reports on the return
for this investment, or (4) to scrutinize funding requests, and
perhaps consider limiting funds, in areas where agencies cannot
provide satisfactory answers to questions raised about the quality of
the data underpinning the request or their ability to properly
account for the expenditures.
These mechanisms--sustained congressional attention as part of the
normal oversight process and agency head accountability--are
essential to continue to effectively implement the financial
management reform legislative foundation the Congress has
established. They are key elements of ensuring that agencies make
the investment of time, talent, and resources necessary to achieve
needed financial management improvements.
With a concerted effort, the federal government, as a whole, can
continue to make progress toward ensuring full accountability and
generating reliable information on a regular basis. Annual financial
statement audits are essential to ensuring the effectiveness of the
improvements now underway and, ultimately, to producing the reliable
and complete information needed by decisionmakers and the public to
evaluate the government's financial performance. They are also
central to assuring taxpayers that their money is being used as
intended and helping the government implement broad management
reforms called for by the Government Performance and Results Act.
--------------------
\7 Internal Revenue Service: Remaining Challenges to Achieve Lasting
Financial Management Improvements (GAO/T-AIMD/GGD-98-139, April 15,
1998).
\8 Financial Audit: Examination of IRS' Fiscal Year 1997 Custodial
Financial Statements (GAO/AIMD-98-77, February 26, 1998).
\9 Financial Management: Forest Service's Progress Toward Financial
Accountability (GAO/AIMD-97-151R, August 29, 1997), Forest Service:
Status of Progress Toward Financial Accountability (GAO/AIMD-98-84,
February 27, 1998, and Forest Service: Lack of Financial and
Performance Accountability Has Resulted in Inefficiency and Waste
(GAO/T-RCED/AIMD-98-135, March 26, 1998).
\10 Financial Management: Comments on DFAS' Draft Federal Accounting
Standards and Requirements (GAO/AIMD-97-108R, June 16, 1997).
\11 Financial Management: DOD Needs to Lower the Disbursement
Prevalidation Threshold (GAO/AIMD-96-82, June 11, 1996).
\12 CFO Act Financial Audits: Programmatic and Budgetary
Implications of Navy Financial Data Deficiencies (GAO/AIMD-98-56,
March 16, 1998).
\13 Financial Management: Federal Aviation Administration Lacked
Accountability for Major Assets (GAO/AIMD-98-62, February 18, 1998).
\14 Financial Management: Implementation of the Federal Financial
Management Improvement Act of 1996 (GAO/AIMD-98-1, October 1, 1997).
\15 The agencies reported to be in substantial compliance are the
Department of Energy, the National Aeronautics and Space
Administration, the National Science Foundation, and the General
Services Administration.
-------------------------------------------------------- Chapter 0:4.1
Mr. Chairman, this concludes my statement. I would be happy to now
respond to any questions that you or other members of the
Subcommittee may have at this time.
STATEMENTS OF FEDERAL FINANCIAL
ACCOUNTING CONCEPTS AND STANDARDS
=========================================================== Appendix I
----------------------------------------------------------------------
Statements of Federal Financial Accounting Concepts (SFFAC)
Objectives of Federal Financial Reporting (SFFAC 1)
Entity and Display (SFFAC 2)
Statements of Federal Financial Accounting Standards (SFFAS)
Accounting for Selected Assets and Liabilities (SFFAS 1)
Accounting for Direct Loans and Loan Guarantees (SFFAS 2)
Accounting for Inventory and Related Property (SFFAS 3)
Managerial Cost Accounting Concepts and Standards (SFFAS 4)
Accounting for Liabilities of the Federal Government (SFFAS 5)
Accounting for Property, Plant, and Equipment (SFFAS 6)
Accounting for Revenue and Other Financing Sources (SFFAS 7)
Supplementary Stewardship Reporting (SFFAS 8)
Deferral of the Effective Date of Managerial Cost Accounting Standards
for the Federal Government in SFFAS 4 (SFFAS 9)
======================================================================
Interpretations
Accounting for Indian Trust Funds (Interpretation 1)
Accounting for Treasury Judgment Fund Transactions (Interpretation 2)
Measurement Date for Pension and Retirement Health Care Liabilities
(Interpretation 3)
Accounting for Pension Payments in Excess of Pension Expense
(Interpretation 4)
----------------------------------------------------------------------
*** End of document. ***