Management's Discussion & Analysis

Financial Management

Grants

In FY 2021, the federal government obligated over $1.2 trillion for grants and cooperative agreements and more when accounting for other types of financial assistance, such as loans and direct appropriations. A large portion of grant funding went to support the nation’s response to the pandemic through the ARP, the CARES Act, and other COVID-19 funding. Recognizing the need to distribute ARP funding in a timely manner and to also ensure accountability, transparency, and program results, OMB issued Memorandum M-21-20, Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources. M-21-20 leveraged ongoing OMB efforts to promote standardization and a shared IT infrastructure, manage risk, and achieve program objectives. It required agencies to apply the requirements of Title 2 of the CFR to all federal financial assistance provided under ARP, to the maximum extent allowed by law, and to consider existing flexibilities in Title 2 of the CFR to both comply with existing requirements and achieve intended program outcomes. Appendix 2 of M-21-20 outlined the flexibilities agencies are required to consider and highlighted Managing for Results: The Performance Management Playbook for Federal Awarding Agencies for new programs. The Playbook promotes a common understanding of performance practices in an effort to improve program performance. M-21-20 also emphasized the importance of award descriptions reported to USAspending.gov and the requirement for agencies to consult the relevant QSMO before developing new or modernized technology or considering an existing provider.

In addition to providing guidance to support proper administration of ARP funding, OMB provided guidance on the administration of other COVID-19 emergency programs. In December 2020, OMB issued audit guidance for fourteen new COVID-19 programs in an addendum to the 2020 Compliance Supplement (which is a compendium of applicable statutory, regulatory, and other requirements relevant to the “single audit” requirements for federal financial assistance recipients, including grant recipients). Recognizing the importance of quality subaward data in tracking COVID-19 funding, the 2020 addendum and 2021 Compliance Supplement include instructions for auditors to review compliance with subaward reporting under the Federal Funding Accountability and Transparency Act. Improving access to key financial assistance data continues to be a priority for OMB and was highlighted in OMB memorandum M-22-02, New Financial Assistance Transparency Requirements, which requires agencies to report additional information to USAspending.gov. Going forward, OMB will continue to prioritize efforts to improve the financial management of grants and other forms of financial assistance, including efforts to improve transparency.

Payment Integrity

Preventing improper payments in the federal government is a management priority. To be successful in preventing improper payments, there must be a focus on systemic enhancements intended to make payments correctly the first time with an emphasis on minimizing monetary loss. The federal government, through the CFO community, continues to develop strategies to better analyze and prevent monetary loss. In FY 2021, OMB published Memorandum M-21-19, Appendix C to OMB Circular No. A-123, Requirements for Payment Integrity Improvement. M-21-19 implements the requirements from the Payment Integrity Information Act of 2019. Also in 2021, the CFO Council published two guides on cfo.gov that provide strategies to identify a “tolerable rate” of improper payments and strategies based on behavioral research.

Since FY 2018, agencies with programs reporting more than $100.0 million in monetary loss have provided a quarterly scorecard on PaymentAccuracy.gov. These scorecards provide information on the actions taken and progress made on preventing improper payments that would result in monetary loss to the government. Additional details on these programs’ FY 2021 improper payment data can be found at https://paymentaccuracy.gov/. Beginning in FY 2020, PaymentAccuracy.gov also began providing payment integrity information that had previously been reported in agencies financial statements. Information about program compliance, corrective actions, and accountability mechanisms is now available in a consistent format across all programs.

OMB will continue to work with agencies, the Chief Financial Officers Council, and other stakeholders to improve the identification of the root causes of improper payments that result in monetary loss and to promote data analytic methods that take a comprehensive view of an agency’s payment lifecycle.

Agency Financial Report Audits

Since the passage of the CFO Act, the federal financial community has made significant progress in financial accounting and reporting. As shown in Table 11, for FY 2021, 21 of the 24 CFO Act agencies obtained an unmodified opinion from the independent auditors on their financial statements.²⁷ In addition, 47 auditor-identified material weaknesses were identified for FY 2021, the same as for FY 2020. Twenty-eight of these are associated with DOD. The other 19 material weaknesses are associated with non-DOD agencies, which represents a slight decline from the 22 reported for FY 2020. Although virtually all federal agencies have adopted and maintained disciplined financial reporting operations, implemented effective internal controls over financial reporting, and integrated transaction processing with accounting records, weaknesses in financial management practices continue to prevent the government as a whole from achieving an audit opinion.

Financial Management Systems

Federal agencies improved, but continue to face challenges, in implementing financial management systems that meet federal requirements. The number of CFO Act agencies reporting lack of substantial compliance with one or more of the three Section 803(a) requirements of the FFMIA increased to eight in FY 2021, and the number of auditors reporting lack of substantial compliance with one or more of the three Section 803(a) FFMIA requirements remained at nine in FY 2021.

Because of the federal government’s size and diversity, its financial management infrastructure consists of both legacy and modernized systems and standardized and customized systems. As the government’s fiscal agent, Treasury works closely with agencies to manage systems for collecting and disbursing the government’s cash and financing disbursements when necessary, recording and reporting on those collections and disbursements, and reporting on all government revenues, expenses, assets, and liabilities.

In 2020, Treasury was designated as the Financial Management Systems QSMO and is pursuing financial management improvement strategies that have government-wide implications. These strategies include standing up a financial management systems marketplace and developing system standards, standardized processes, system requirements, and system interfaces. These efforts provide a path to the decommissioning of legacy systems and migration to updated systems, leveraging modernized technologies. In addition, agencies are coordinating with the Treasury QSMO to improve their financial management and financial reporting systems as described in their financial reports, Congressional budget justifications, and performance plans. DOD continues to address its material weaknesses in financial reporting, and is bringing its financial systems into compliance with federal financial management systems requirements, including the FFMIA.

In January 2021, the HHS was designated as the Grants QSMO. In this capacity, HHS has been and will continue working to modernize and streamline the government’s vast and aging legacy grants management systems. The goal of this effort is to allow agencies to successfully manage grants through the entire award cycle and allow grants management systems to interface with agency financial management systems.

Internal Controls

Federal managers are responsible for developing and maintaining effective internal controls. Internal controls help to ensure effective and efficient operations, reliable financial reporting, and compliance with applicable laws and regulations. Safeguarding assets is a goal of each of these three objectives.

OMB Circular No. A-123 implements the requirements of 31 U.S.C. 3512 (c) and (d) (commonly known as the Federal Managers’ Financial Integrity Act) by providing agencies a framework for assessing and managing risks strategically and tactically. The Circular reflects GAO’s Standards for Internal Control in the Federal Government and contains multiple appendices that address one or more of the objectives of effective internal control.

• Appendix A provides for agencies to use a risk-based approach to assess, document, test, and report on internal controls over reporting and data integrity;
• Appendix B requires agencies to maintain internal controls that reduce the risk of fraud, waste, and error in government charge card programs;
• Appendix C implements the requirements for effective estimation and remediation of improper payments; and
• Appendix D defines requirements for determining compliance with the FFMIA that are intended to reduce the cost, risk, and complexity of financial system modernizations.

As noted above, the total number of reported material weaknesses for CFO Act agencies was 47 for FY 2021, the same as for FY 2020. Effective internal controls are a challenge at the agency level and at the government-wide level, with GAO reporting that at the government-wide level, material weaknesses resulted in ineffective internal control over financial reporting. While progress is being made at many agencies and across the government in identifying and resolving internal control deficiencies, additional work is needed.

Legal Compliance

Federal agencies are required to comply with a wide range of laws and regulations, including appropriations, employment, and health and safety, among others. Responsibility for compliance rests with agency management and compliance is addressed as part of agency financial statement audits. Agency auditors test for compliance with selected laws and regulations related to financial reporting and certain individual agency audit reports contain instances of noncompliance. None of these instances were material to the government-wide financial statements; however, GAO reported that its work on compliance with laws and regulations was limited by the material weaknesses and scope limitations discussed in its report.

Conclusion

The federal government has seen significant progress in financial management since the passage of the CFO Act more than 30 years ago, but significant challenges remain to realizing the intended financial management reforms of the act. The issues that the federal government faces today require financial managers to improve both the efficiency and effectiveness of financial management activities, which includes moving toward integrated government operations with standardized business processes, systems, and data. Together with Treasury and OMB, agencies are building on tools and capabilities to improve financial accountability and transparency.

Footnotes

²⁷ The 22 entities include HHS, which received an unmodified (“clean”) opinion on all statements except the SOSI and the SCSIA. (Back to Content)