394037_AGA:394034_AGA 6/25/10 4:15 AM Page 1

Redefining Accountability Recovery Act Practices and Opportunities

AGA CPAG Research Series: Report No. 25 July 2010

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 2

ACKNOWLEDGEMENTS About the Authors Relmond P. Van Daniker, DBA, CPA, is the executive director of the Association of Government Accountants (AGA). Prior to this position, he spent 25 years as the executive director of the National Association of State Auditors, Comptrollers and Treasurers (NASACT). Van Daniker is a past national president of the International Consortium on Governmental Financial Management and was a professor of accounting at the University of Kentucky for 30 years. He also served as assistant director with the Cost Accounting Standards Board. Helena G. Sims is the director of Intergovernmental Relations for AGA. Prior to her work with AGA, she was managing director of Public-Private Partnerships for a banking trade association that played a key role in developing a nationwide system for the electronic delivery of government benefits. She served as Washington office director for NASACT and has also worked for the Council of State Governments, the U.S. Senate and the Florida Legislature. The views expressed are those of the authors and not necessarily the views of AGA. Project Advisor David M. Zavada, MPA, CPA, Partner, Kearney & Company; Former Chief, Financial Standards and Grants Branch, Office of Federal Financial Management, Office of Management and Budget

Corporate Partner Advisory Group Leadership Chairman Hank Steininger, CGFM, CPA Managing Partner, Global Public Sector, Grant Thornton LLP Vice Chairman John Cherbini, CGFM, CPA Partner, KPMG LLP

AGA Professional Staff Relmond Van Daniker, DBA, CPA Executive Director Anna D. Gowans Miller, MBA, CPA Director of Research Susan Fritzlen Director of Corporate Partner Program Marie Force Director of Communications Christina Camara Publications Manager

Thank You To Those Interviewed AGA is also pleased to recognize those interviewed or contributing to this report: Lisa Allen, chief of staff, Office of the Inspector General, U.S. Department of Commerce Owen Barwell, deputy chief financial officer, U.S. Department of Energy Sheila Conley, CGFM, CPA, deputy chief financial officer, U.S. Department of Health and Human Services Roldan Fernandez, CGFM, CPA Senior Partner, Kearney & Company Melissa Heist, CGFM, CPA, assistant inspector general for audit, U.S. Environmental Protection Agency Matthew A. Jadacki, CGFM, CPA, deputy inspector general, Office of Emergency Management Oversight, U.S. Department of Homeland Security Kristine Leiphart, former deputy chief financial officer, Federal Transit Administration, U.S. Department of Transportation Phil Maestri, director, Risk Management Service, Office of the Secretary, U.S. Department of Education

Melinda Morgan, director, finance staff, U.S. Department of Justice William A. Morehead, Ph.D., CGFM, CPA, chair of Accountancy, Computer Information Systems and Finance, associate professor, Delta State University; AGA 2009–2010 National President Marcia Paull, CGFM, chief financial officer, Office of Justice Programs, U.S. Department of Justice John Radford, CGFM, CIA, CFE, state controller, State of Oregon Richard Skinner, inspector general, U.S. Department of Homeland Security James Taylor, principal deputy inspector general, U.S. Department of Homeland Security Robert Tuccillo, chief financial officer, Federal Transit Administration, U.S. Department of Transportation Danny Werfel, Controller, Office of Federal Financial Management, U.S. Office of Management and Budget Todd Zinser, inspector general, U.S. Department of Commerce

AGA is Proud to Recognize the Firm Supporting this Effort:

2 AGA Corporate Partner Advisory Group Research

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 3

TABLE OF CONTENTS/CPAG ADVISORY GROUP Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Impetus for Change . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 The Hurricane’s Wake . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 The Recovery Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Recovery Act Management and Accountability Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Aggressive Risk Assessment and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Federal Transit Administration Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Proactive “Prevention-Oriented” Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 More Detailed and Transparent Financial Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Greater Intergovernmental Communication and Cooperation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Leveraging Recovery Act Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Risk Assessment and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 Financial Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Accumulating Data Versus Providing Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Data Integrity and Assurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Citizen-Centric Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 Intergovernmental Cooperation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

AGA’s Corporate Partner Advisory Group Research Program: Building the Bridge Between Government and Industry AGA’s Corporate Partner Advisory Group (CPAG), executive director and director of research are creating research projects of value to governments, industry and the entire AGA membership. These studies are expected to result in reports assessing current and/or best practices and make recommendations for future improvements in federal, state and local governmental accounting, auditing and financial management. CPAG members support AGA research through either cooperative or sponsored research projects. “By undertaking research, AGA is fulfilling its mission as a thought leader in advancing government accountability,” said AGA Executive Director Relmond Van Daniker, DBA, CPA. “This is one of numerous research initiatives that will benefit government and bridge the gap between the public and private sectors.”

The CPAG was organized in 2001 as a business element within AGA. The mission of the CPAG is to bring industry and government executives together to exchange information, support professional development, improve communications and understanding, solve issues and build partnership and trust, thereby enhancing AGA’s focus on advancing government accountability. Corporate member involvement in the CPAG is limited to organizations that sign up for the AGA Corporate Partner membership program. For more information on the research program, please visit www.agacgfm.org/research/default.aspx or contact Anna Miller at [email protected].

July 2010 3

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 4

REDEFINING ACCOUNTABILITY Introduction

“First and foremost is the public mandate for increased accountability and transparency at all levels of government. Hurricane Katrina brought more attention to the problems and risks associated with the management of large grants and contracts that are awarded in a hasty fashion.” —Richard Skinner, Inspector General, U.S. Department of Homeland Security

Executive Summary In implementing the American Recovery and Reinvestment Act of 2009 (Recovery Act), federal agencies have introduced more aggressive risk management, strengthened oversight, incorporated more detailed financial reporting, and implemented other practices to enhance transparency and accountability over government financial management. Some of these practices were the result of lessons learned from earlier similar circumstances, while others represented an emphasis on existing transparency requirements. Regardless, these practices are innovative—and in some cases unprecedented—and have the potential to shape future government financial management and reporting. The economic events that rocked the United States in 2008–2009 created a need for the federal government to act quickly and effectively to stabilize and stimulate the U.S. economy. In 2009, unemployment rose, home foreclosures skyrocketed, banks and businesses failed, and the federal government responded with massive recovery packages. The Recovery Act was enacted to address these needs and called for $787 billion to stimulate the economy, with most outlays scheduled over two years. Along with the stimulus funds, the Recovery Act called for unprecedented levels of transparency and oversight to address the risk of executing such large programs over such a short period of time. All too recent was the experience with Hurricane Katrina in 2005, where fraud, waste and abuse plagued the government’s rescue efforts. The administration, Congress and federal financial management and accountability professionals were determined not to let this happen with Recovery Act funds. In implementing this legislation, these professionals aimed to do all they could to ensure that funds would be directed as intended and that spending would be transparent to the public. This report focuses on the implementation of the Recovery Act and how new and innovative management and accountability practices have been developed to proactively assess risk, provide oversight, add greater transparency and accountability, and communicate with intergovernmental funding recipients. These practices represent a focused effort to ensure sound management and accountability of Recovery Act funds. This report looks at each one of these practices in detail and identifies opportunities to adapt or learn from them on a broader government-wide scale.

4 AGA Corporate Partner Advisory Group Research

Over the past 20 years, a foundation of sound federal financial management practices has developed into the management and framework in place today. However, the new requirements, needs and risks associated with the Recovery Act have shifted the focus within this framework. While implementing the Recovery Act, practices emerged that adapted and extended the existing federal management and accountability framework. For example, in the areas of risk management and internal controls, the recent emphasis has been on documentation, testing and compliance. The Recovery Act legislation has shifted the focus to risk assessment and prevention. The challenge ahead is to identify opportunities to effectively and efficiently adapt and adjust the management and accountability framework to enable improved management and accountability across all government programs.

The Impetus for Change The Hurricane’s Wake Despite the public’s outpouring of support to the victims of Hurricane Katrina in September 2005, there was palpable disappointment in the lack of stewardship over public funds. For the Individuals and Households Program alone, the U.S. Government Accountability Office (GAO) estimated that the Federal Emergency Management Agency (FEMA) made about 16 percent, or almost $1 billion, in improper and potentially fraudulent payments to registrants who applied using invalid information, illustrating the need for effective prevention controls.1 Hurricane Katrina severely tested disaster management officials at all levels of government, and many lessons were learned from that experience. Richard Skinner, inspector general at the U.S. Department of Homeland Security (DHS), said that he believes the lessons learned were substantial. “First and foremost is the public mandate for increased accountability and transparency at all levels of government,” Skinner said. “Hurricane Katrina brought more attention to the problems and risks associated with the management of large grants and contracts that are awarded in a hasty fashion.” As with other areas, financial management problems centered on the lack of preparedness, in terms of understanding program and reporting risks, and taking steps to mitigate them to the extent possible through additional internal controls. The Hurricane Katrina experience highlighted the need to ramp up risk management, internal controls and oversight in situations where large outlays and a condensed timeline elevate financial risk. This is a central financial management and accountability lesson learned from Hurricane Katrina. Ramping up oversight early was another lesson from Katrina. Early indications of an elevated risk of fraud, waste and abuse set into action a joint cross-agency task force of inspectors general, chaired by Skinner. The task force launched a series of coordinated oversight efforts and issued periodic short-term reports with the aim of deterring fraud, waste and abuse.

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 5

RECOVERY ACT PRACTICES AND OPPORTUNITIES In addition, to provide ongoing real-time oversight of Katrina recovery efforts and FEMA programs, Skinner established an Office of Emergency Management Oversight, which reports directly to him. Matthew Jadacki, CGFM, CPA, was appointed as the deputy inspector general with the focused responsibility for disaster oversight. In many ways, the recent memory of Hurricane Katrina helped set the tone for the collective transparency, accountability and oversight that would be a significant part of implementing the Recovery Act legislation. The Recovery Act The groundwork for more detailed reporting of grant and contract information was already laid with the enactment of the Federal Funding Accountability and Transparency Act (Transparency Act) in September 2006. The Transparency Act required the U.S. Office of Management and Budget (OMB) to establish and maintain USASpending.gov, a public website where federal agencies are required to post detailed spending information on federal

grants and contracts. The mindset that promotes greater transparency in seeing the details of government grants and contracts translates to better accountability over the use of government funds. The intent of the Transparency Act aligned well with the desire to demonstrate accountability over Recovery Act funds. Combined with the large sums of money being spent on economic recovery in other economic stabilization legislation, such as the Emergency Economic Stabilization Act of 2008, the Transparency Act positioned the Recovery Act for unprecedented management attention, reporting and oversight. In February 2009, the Recovery Act was enacted. The Recovery Act provided for $787 billion in funding with the intent to invest in and stimulate the U.S. economy. The Recovery Act provides funding in more than 25 federal agencies. The $787 billion is comprised of the following major categories, which are highlighted in Figure 1.

Figure 1: Recovery Act Funding by Category For grants, contracts and loans, the Recovery Act contains detailed reporting requirements for federal agencies and recipients of funding, and has defined a new level of government transparency and accountability. It established direct, online reporting to the public via the Recovery.gov website. The recipients of Recovery Act funds are required to report their spending, as well as other information, within 10 days after the close of a financial quarter. Sub-recipients are also required to report spending through a newly developed website, FederalReporting.gov. This not only represents a significant acceleration in reporting timeframes, but also a dramatic change in the level and method by which financial information is reported. The Recovery Act also established the Recovery Accountability and Transparency Board (RATB). The RATB is comprised of federal inspectors general and is charged with coordinating oversight over Recovery Act funds, and establishing and maintaining the Recovery.gov website. In addition to the statutory requirements, Vice President Joseph Biden has been directly involved in Recovery Act oversight. He has established a clear tone at the top that fraud, waste and abuse will not be tolerated. This tone at the top has had a significant impact on the collective internal control environment surrounding the Recovery Act, to include more robust risk assessment practices, improved communication and training with grantees and other recipients. Further, guidance issued by OMB in the areas of risk management, internal controls and actions taken by federal agencies to implement these requirements has collectively resulted in a high level of management attention to these funds. In translating the statutory and OMB requirements into action, certain leading practices have emerged and are re-defining accountability over government programs. These practices are discussed in the following sections.

July 2010 5

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 6

REDEFINING ACCOUNTABILITY “To meet A-123’s requirements, agencies had to establish a governance structure and an assessment process that they were able to leverage in complying with provisions in the Recovery Act.” —James L. Taylor, Deputy Inspector General, U.S. Department of Homeland Security

Recovery Act Management and Accountability Practices Aggressive Risk Assessment and Management The focus on risk management and internal control has shifted in intensity over the years. While many definitions of risk management exist, risk management in its simplest form is essentially the process of identifying, assessing and analyzing potential threats to develop (when necessary) controlling or preventative processes and procedures to avoid outcomes inconsistent with program objectives or reporting standards. Hence, risk assessment and internal controls are an integral and essential part of the overall risk management process. The enactment of the Federal Manager’s Financial Integrity Act (FMFIA) of 1982 placed a statutory emphasis on the importance of internal control to achieving program results, complying with legal requirements and reporting accurate financial information. In recent years, OMB issued revised guidance on assessing internal control over financial reporting in OMB Circular A-123, Management’s Responsibility for Internal Control, Appendix A. The introduction of the Appendix A requirements fueled a renewed emphasis on the importance of internal controls within federal agencies. As a result of Appendix A, new governance structures and assessment processes were established or given greater stature. Senior assessment teams comprised of representatives from various financial and financial-related offices were established to conduct and monitor the assessment of internal control, along with internal control deficiencies and weaknesses. In implementing the Recovery Act, many agencies have been quick to recognize that this framework and assessment process is something that can be leveraged to address Recovery Act risks. James L. Taylor, deputy inspector general at DHS, said earlier this year that he believed Appendix A has helped to prepare agencies for managing Recovery Act programs: “To meet A-123’s requirements, agencies had to establish a governance structure and an assessment process that they were able to leverage in complying with provisions in the Recovery Act.”

6 AGA Corporate Partner Advisory Group Research

Taylor went on to add that much of the risk is at the local level with governments receiving funding that is subjected to new reporting requirements. As is often the case with disasters, these governments are not prepared and do not have the capacity to handle these new programs and requirements. The Recovery Act is an opportunity to take a positive step forward, Taylor said, adding that it has raised the bar for financial management. However, much of the emphasis in implementing Appendix A requirements has been placed on the documentation and testing phases of the assessment process. While this emphasis is necessary to understand financial processes and determine internal control effectiveness, the initial risk assessment part of the process was less understood. David M. Zavada, CPA, a partner with Kearney & Company and a former OMB executive involved in developing the Appendix A process, said: “Prior to the Recovery Act, the risk assessment part of the internal control assessment process was less understood. It was more of a lofty and amorphous process, and more difficult for management to get their hands around than the documentation and testing phases. The Recovery Act has moved risk assessment and management to the forefront.” Under the Recovery Act, the risk assessment process of articulating, discussing and drawing upon available data to pinpoint risk areas or recipients is being taken to a deeper level. The outcome of the risk assessment process is being used in a more meaningful way to shape risk management plans and internal control actions for Recovery Act programs. Federal Transit Administration Approach At the Federal Transit Administration (FTA) within the Department of Transportation (DOT), management has implemented a risk management process that leverages Appendix A assessment along with other internal assessment programs and data. FTA placed unprecedented emphasis on risk assessment practices, hoping to reduce the impact of fraud, waste and abuse of these critical funds. FTA has taken extra steps to use existing knowledge and information to better understand and target program oversight efforts. FTA received $8.4 billion in Recovery Act funds for three major grant programs: Transit Capital Assistance Program, Fixed Guideway Infrastructure Investment Program and Capital Investment Grants Program.The magnitude of these funds in relation to FTA’s existing budget and the timeline for awarding and outlaying funds prompted FTA to develop a risk management plan.

Built on a DOT-wide risk management strategy developed as part to the DOT Transportation Investment Generating Economic Recovery (TIGER) initiative, DOT and FTA were quick to develop a comprehensive four-phased risk management framework to address Recovery Act risks and

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 7

RECOVERY ACT PRACTICES AND OPPORTUNITIES implement effective internal controls. The four-phased plan includes: • Phase 1: Risk Assessment Questionnaire • Phase 2: Risk Profile • Phase 3: Risk Mitigation Strategy Template • Phase 4: Risk Strategy Validation and Testing. The plan leverages and integrates the Appendix A internal control assessment process, along with the FTA Office of Program Management’s Triennial Review Program, into Recovery Act risk management and oversight. According to Kristine Leiphart, FTA’s former deputy chief financial officer, the primary goals of this plan are to increase efficiency and transparency in the allocation and expenditure of Recovery Act funds, implement new accountability requirements and programs mandated by Recovery Act, and combat fraud, waste and abuse. The risk-based approach was used to identify recipients requiring additional monitoring, oversight and technical assistance. The system compiles a rating of high, medium or low based on the answers and weights to the sections. The ratings are compiled in a national grantee analysis with other data, including materiality and open single audit findings. Headquarters personnel review the grantee analysis to help ensure adequate oversight based on available data and resources. Other agencies have followed a similar course of action in assessing risk over programs receiving Recovery Act funds. The U.S. Department of Justice (DOJ) used single audit results as a source of data to build a risk profile of Recovery Act grant recipients. The U.S. Departments of Energy and Education have put risk management strategies in place, and have integrated and leveraged the OMB Circular A-123 assessment process to better understand and assess risks related to Recovery Act funding. Phil Maestri, director of Risk Management at Education, said much of the money his department would be overseeing was in the form of add-ons to existing grants. Education put its emphasis on “accelerated strategic spending,” or, in other words, making sure decisions were made strategically and not just expediently. “We’re more interested in spending right than spending quickly,” he said. To mitigate the risk, Education developed a technical assistance program as well as other risk mitigation efforts in the areas of training, performance indicators and additional monitoring. Proactive “Prevention-Oriented” Oversight Early in the implementation of the Recovery Act, the RATB adopted a coordinated oversight approach based on the early identification of risks. Rather than audit after the fact and report on mistakes made, inspectors general were called upon to take a more proactive “prevention-oriented” approach. This approach was aimed at auditing and reporting sooner in the program execution process to yield benefits in the form of preventing wasteful spending. To do this, RATB took a real-time approach to conducting its audits, attempting to identify risks for wasteful spending, program failure and data integrity. RATB Chairman Earl E. Devaney

commented on the increased emphasis on prevention at AGA’s Fourth Annual Internal Control and Fraud Conference in Washington, D.C. on September 16, 2009. He said that early on in the Recovery Act process, federal inspectors general met and agreed that the Recovery Act called for a different approach to detect fraud, waste and abuse than looking at things after the fact and realizing something had happened. “We had to get our heads around prevention,” Devaney said. “What can we do on the front end of this pipeline?” DHS Inspector General Richard Skinner noted that to address these concerns, Congress created the RATB to: establish and maintain a user-friendly, public-facing website (Recovery.gov) to foster greater accountability and transparency of Recovery funds and coordinate and conduct oversight of Recovery spending to prevent fraud, waste and abuse. In addition, the RATB serves as an ongoing forum for communication and coordination among the inspectors general offices involved in Recovery Act oversight, state and local oversight partners and GAO. The Recovery Act also provided funding for ongoing oversight from GAO and agency inspectors general. Interviewed as the Recovery Act implementation was just beginning, Todd Zinser, inspector general at the U.S. Department of Commerce, indicated that his office would be placing a strong emphasis in the area of front-end prevention. The goal was to identify risks earlier by reviewing management’s risk management plans. This new approach would be combined with investigations to identify and prosecute incidents of fraud. Zinser’s office is relying on cutting edge “OIG Recovery Act Flash Reports” to get the word out on lessons learned and actions the program managers can take to effectively mitigate risk and reduce the opportunities for fraud. These early reports drew from past audits over the program, along with the collective current knowledge of program experts, to assess and identify areas where management capacity and capability risks existed. Many inspector general offices conducted similar “early warning” reports—reports that, because of their timing, had the opportunity to shape management implementation and prevent fraud, waste and abuse. More Detailed and Transparent Financial Reporting Accountability and transparency go hand in hand. Under the Recovery Act, the reporting of detailed financial information on public websites is a means of being transparent, and in turn, more financially accountable. First the Transparency Act and now the Recovery Act have greatly increased the amount of financial information publicly reported by federal agencies and recipients of federal funding. While some level of detailed financial information has always been reported in the president’s budget, agency budget justifications and agency Performance and Accountability Reports, this level of detailed information publicly reported and posted on the Internet is unprecedented. In

July 2010 7

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 8

REDEFINING ACCOUNTABILITY “Prior to the Recovery Act, the risk assessment part of the internal control assessment process was less understood. It was more of a lofty and amorphous process, and more difficult for management to get their hands around than the documentation and testing phases. The Recovery Act has moved risk assessment and management to the forefront.” —David M. Zavada, Partner, Kearney & Company addition, while federal spending information by geographic area has been reported in the past, the information was not reported so quickly and in such a widely accessible format. Under the Transparency Act, federal agency grant and contract information is required to be posted on USAspending.gov. Similarly, many states and local governments took steps to publish their “checkbooks” online. While this was an innovative idea at the time, the notion of reporting detailed financial information on public websites was accelerated with the enactment of the Recovery Act. In addition, the Recovery Act requires both recipient and sub-recipient reporting to Recovery.gov. Recovery Act reporting is a massive undertaking. More than 130,000 entities from all levels of government, as well as nonprofit organizations, are reporting to a new central database, FederalReporting.gov. Reports must be filed with unprecedented speed using new formats. The initial Recovery Act reporting marked the beginning of a new era in government transparency. Now, Recovery Act reporting has introduced a broad range of publicly reported financial information. Some of the newly required information, such as obligations and outlays by program, are available in existing financial management systems. However, much of the other detailed information is not readily available in existing systems. The development of this detailed information requires special data calls and inquiries. Similar information is being reported on different websites, leading to the need for adequate internal controls over this information. As the Recovery Act has been implemented and is now over a year old, improved linkages are being made between the information reported and existing requirements. For example, although it is broader and subject to slightly different requirements, the federal spending information reported on USAspending.gov to meet the Transparency Act requirements is similar to the grants and contract information reported on Recovery.gov. The information to meet both reporting requirements is derived from a variety of financial and program systems, some of which may be outside of the independent audit and internal control assessment process. Better linkages between systems are being made, and the

8 AGA Corporate Partner Advisory Group Research

internal controls over this information are quickly catching up with the reporting. Federal managers face two primary challenges related to this broader and more detailed spending information being reported. The first challenge is to ensure spending information is timely and accurate by establishing internal controls over the information being reported. The second challenge is to develop ways to array and build off of the basic spending information to make it more useful and understandable to users. On December 8, 2009, the president issued the Open Government Directive. Section 2 of the directive specifically addressed the quality of information reported publicly. On February 8, 2010, OMB issued its Framework for the Quality of Federal Spending Information as a followup to the directive. The February guidance calls for adapting elements of the OMB Circular A-123 assessment process for federal spending information to ensure that internal controls over the financial data reported on public websites are in place and operating effectively. Federal agencies such as the National Aeronautics and Space Administration (NASA) have developed Open Government Implementation Plans that define strategies for implementing the new requirements agency-wide. NASA’s open government implementation plans include a data quality and integrity strategy that leverages and aligns with its OMB Circular A-123 internal control assessment process. Greater Intergovernmental Communication and Cooperation The implementation of the Recovery Act is also promoting a new era of cooperation and collaboration among governments, in part because governments must work together to implement the act and meet associated public expectations. RATB Chairman Earl Devaney stated that the focus of the federal government has been on training along with state and local partners. He noted that thousands of people have been trained, and that RATB is monitoring every Recovery Act contract. Devaney said, “It’s the right thing to do in this type of situation. We’re leveraging all kinds of partnerships.” Governors, mayors and inspectors general want to avoid potential embarrassments. In all his years in the government, Devaney said he has never seen state, local and federal authorities working together the way they have on the Recovery Act. “The risks are so profound, and we all share that risk.” AGA conducted regional dialogues so that officials at all levels of government could have face-to-face conversations about their implementation experiences. Between May and September 2009, AGA conducted four regional dialogues in Baltimore, MD; Portland, OR; Kansas City, MO; and Boston, MA, that were attended by nearly 1,000 people. During these sessions, OMB and numerous federal agencies updated state and local officials on Recovery Act implementation and listened to what their state and local counterparts had to say about the Recovery Act. To ensure that the federal government obtained solid grassroots input, AGA worked closely with its chapters in organizing the dialogues. The dialogues provided an excellent forum for the candid and

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 9

RECOVERY ACT PRACTICES AND OPPORTUNITIES open exchange of information between governments. This kind of dialogue will become more important as governments work together to populate databases, especially when the databases are subject to extensive public scrutiny. Communication among federal, state and local governments is being enhanced as a result of the Recovery Act. Agencies such as DOJ and DOT, which provide Recovery Act funding directly to local police departments and transit agencies, are stepping up training, webinars and other outreach efforts, such as AGA forums and panels, to communicate Recovery Act requirements. Experience in implementing the Recovery Act has demonstrated that some grantees and federal agencies need additional technical assistance to maintain compliance with Recovery Act requirements, including those that apply to all recipients of federal funding as conditions of eligibility. FTA has addressed this need by providing customized technical assistance to grantees on an as-needed basis in the form of site visits, regular correspondence, assistance in closing findings and resolving outstanding issues, and more. A similar effort has been undertaken at the DOJ Office of Justice Programs (OJP) where extensive outreach, webinars and trainings have been provided to grantees on the Recovery Act requirements. FTA and OJP also provide technical assistance in advance of oversight reviews to directly educate grantees on requirements. This outreach has helped to fill the communication gap between federal, state and local governments regarding Recovery Act implementation. Other key intergovernmental initiatives spawned by the Recovery Act include: • A series of free educational webinars conducted by OMB in August 2009. The webinars were made available free to those involved with implementation. In addition, some federal agencies, such as Education, conducted regularly scheduled webinars on the Recovery Act’s implementation. • A call center was established for those required to file reports with FederalReporting.gov. • Onsite technical support is being provided to some recipients of Recovery Act funding. • Answers to frequently asked questions are posted online by OMB every two weeks. • OMB, federal agencies, GAO, RATB, and state and local government officials agreed to participate in AGA’s intergovernmental dialogues. However, there is no government-sponsored body charged with providing an ongoing forum for intergovernmental cooperation. Not since the Advisory Commission on Intergovernmental Relations closed its doors on September 30, 1996 has there been such a federally funded forum. With the shutting of the commission’s doors, the federal government lost its last resource for addressing broad intergovernmental issues beyond the confines of individual programs.

Leveraging Recovery Act Practices With the Recovery Act implementation more than a year old, the questions at hand for financial managers and policy-makers at all levels of government are, “What opportunities might there be to leverage Recovery Act implementation practices on a broader, government-wide, scale?” and “What are the lessons learned?” The current management and accountability framework at the federal level has mostly developed over the last 20 years. The framework is rooted in a number of laws and OMB guidance, among them are: the FMFIA; the CFO Act of 1990; the Government Management Reform Act of 1994 (GMRA); the Government Performance and Results Act of 1993 (GPRA); Federal Financial Management Improvement Act (FFMIA) of 1996; the Improper Payments Information Act of 2002 (IPIA); OMB Circular A-136, Financial Reporting Requirements; OMB Circular A-123, Management’s Responsibility for Internal Control; OMB Circular A-11 Preparation, Submission and Execution of the Budget; and OMB Bulletin 0704, Audit Requirements for Federal Financial Statements, as amended. In addition to the statutory requirements and OMB guidance, the Federal Accounting Standards Advisory Board (FASAB) was established. FASAB provides a forum for the discussion and recommendation of generally accepted accounting principles (GAAP) for federal agencies. GAAP require independence and due process, such as public comment periods, before approved standards can be “generally accepted.” FASAB offers one of the few forums where OMB, GAO, the U.S. Department of the Treasury and the public interact to advise the executive branch on accounting standards. In addition to accounting standards, GAO has updated and revised its Government Auditing Standards (Yellow Book) dictating the standards for conducting audits at all levels of government. The structure around federal financial reporting, accounting and audit processes represents a tremendous stride forward from the days when accounting practices were not consistent and regular financial audits were not performed. The result has been a steady improvement in the underlying processes and internal controls around financial information, driven by annual independent financial statement audits. Now, in most agencies, regular key reconciliations are performed, fundamental general ledger controls are in place, and annual assessments and audits help ensure that these controls are maintained. These fundamental accounting disciplines and internal controls are essential to the integrity of all financial data, whether the data is used by management for decision-making, reported in budget documents or financial statements, or reported in detail on public websites such as Recovery.gov or USAspending.gov. As the federal financial management community looks ahead on the eve of the 20th anniversary of the CFO Act, a challenge is how Recovery Act practices might be integrated into a stronger, more transparent, and more accountable management and accountability framework. For example, a better understanding of risk allows management to better

July 2010 9

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 10

REDEFINING ACCOUNTABILITY “The main issue here is dealing with a smaller work force with increasing workloads. With a reduced work force, the quality of financial management processes is generally reduced, either in scope or timeliness.… Without a strong internal and external audit presence, financial management discipline practices will shrink in a race to the bottom causing downstream management and crisis issues.”

—John J. Radford, CGFM, CIA, CFE, Controller, State of Oregon target limited resources in implementing and assessing internal controls. Similarly, more proactive oversight at the beginning of what is identified as a high-risk project has cost avoidance benefits and can shape programs in a way that prevents waste from occurring. Further, Recovery Act reporting has introduced a new level of detail and transparency to public financial reporting. In implementing the Recovery Act, enormous effort has been poured into making sure that fraud, waste and abuse are kept to a minimum. Employees at all levels of government have been working feverishly to provide the appropriate scrutiny for Recovery Act funds, and experts wonder if the effort is sustainable. Information recently compiled by NASACT revealed the challenges faced by states in complying with Recovery Act reporting requirements. One state comptroller reported that during the first quarter following the law’s passage, he spent approximately 83 percent of his time dealing with Recovery Act-related issues—at a significant detriment to other equally pressing concerns. Others have lamented the lack of implementation funding for the states, which, combined with tax revenue losses, is creating a dire situation for CFO/comptroller operations. Oregon Controller John J. Radford, CGFM, CIA, CFE, explained that states are grappling with budget reductions along with increasing reporting requirements in a variety of areas, not just the Recovery Act. “The main issue here is dealing with a smaller work force with increasing workloads,” Radford said. “With a reduced work force, the quality of financial management processes is generally reduced, either in scope or timeliness.… Without a strong internal and external audit presence, financial management discipline practices will shrink in a race to the bottom causing downstream management and crisis issues.” A number of federal offices reported similar budgetary pressures on their operations as a result of the caution associated with distributing Recovery Act funds. One large federal agency that received billions in Recovery Act funds spent hours poring over the details of a $100,000 contract after a high-level official raised questions. While good stewardship demands caution, it is usually not possible to focus such intense scrutiny on a contract that pales in comparison

10 AGA Corporate Partner Advisory Group Research

to the size of many of the agency’s more significant contracts. In addition, raw data provided to the public can be wildly misinterpreted. AGA 2009–2010 National President William A. Morehead, Ph.D., CGFM, CPA, chair of Accountancy, CIS and Finance at Delta State University, observed that examples exist where the payments were legal, appropriate and necessary, but appeared wasteful and generated calls from the public. “And, yes, while we must provide transparency to our citizens, answering these calls took precious time away from staff duties to investigate. When states are already struggling with having an adequate number of staff to do their jobs, particularly due to budget cuts and layoffs, answering these types of calls will only slow down other more relevant and important tasks.” For the initial start-up period of the Recovery Act, many career civil servants rose to the occasion in a crisis-like atmosphere. However, sustaining these practices will require an ongoing balance and the need for an understanding of the benefits and costs of managing different levels of risk. Risk Assessment and Management Federal agencies clearly ramped up their focus on risk assessment and the management of risk through the use of internal controls in implementing Recovery Act programs. The risk assessment process related to Recovery Act funds was a meaningful crosscutting process. Out of this process came a good understanding of the specific risks associated with expedited program funding and vulnerable areas where additional internal controls could be introduced to mitigate risk. Risks related to Recovery Act funds not being spent as intended or not being reported accurately were being assessed, understood and addressed in a proactive fashion. The opportunity ahead is to apply elements of this robust risk assessment and aggressive risk management to other programs and financial reporting areas. This does not mean that every contract is pored over, but that risks are understood to the point that limited resources can be applied to the areas where the greatest risk exist, and that these risks can be effectively mitigated. This is the opportunity coming out of the Recovery Act that has broader potential application. This is also the type of proactive risk assessment envisioned by OMB Circular A-123 when Appendix A was implemented. While Appendix A deals specifically with financial reporting risks, the assessment methodology can be applied across all program and financial reporting areas. A Circular A-123 compliance program provides both the governance and methodology to assess and manage risks through effective internal controls. The opportunity that exists for federal agencies is to build upon the relationships, understanding, and other resources used to assess and understand risk related to Recovery Act funds to ensure a robust, proactive, meaningful and effective risk management and internal control program agency-wide.

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 11

RECOVERY ACT PRACTICES AND OPPORTUNITIES Oversight As Devaney commented at AGA’s 2009 Internal Control and Fraud Conference, auditors must strive “…to get our heads around prevention,” and determine what can be done “…on the front end of this pipeline.” In addition, when it comes to progress with intergovernmental entities, it is critical for auditors at all levels of government to work together, not only in getting the broadest audit coverage, but in determining how fraud, waste and abuse can be deterred on the front end of program operations. This type of audit approach is especially relevant to fastchanging, higher-risk situations. For example, during the early years of the formation of DHS, the office of the inspector general used this type of audit approach across many of its programs. Real-time performance audits in the areas of acquisition management and financial management helped to shape and guide program effectiveness and management capabilities in these important areas. The practice of performing prevention-oriented audits in cases where high risks of fraud, waste and abuse are present is a practice that could be applied more broadly. Financial Reporting As indicated by the AGA Survey on Citizen Perceptions on Financial Reporting, the public is dissatisfied with the type of financial information currently being reported by governments. While audited financial statements have maintained a focus on the underlying systems and controls important to any type of internal and external financial reporting, the utility of financial information reported has fallen short. The Recovery Act provides an opportunity to re-assess users and their needs, and look for efficiencies in reporting timely, accurate and reliable information across the board. Accumulating Data Versus Providing Information A broad range of financial data is now being reported on USAspending.gov, Recovery.gov, financial statements, Performance and Accountability Reports and budget documents. The public has access to maps and other tools that can help them determine how much money was spent— even down to spending in a specific ZIP code. However, despite all this available data, it is unclear how useful it is in measuring the effectiveness and accountability of government programs. CNN recently reported that there is a booming interest in data visualization, which can transform boring statistics into compelling graphical presentations explaining our world. Government financial and other data is increasingly being reported and becoming available broadly on the Internet. However, the data being reported is exceeding our ability to analyze, visualize and interpret the information. How useful will it be to know that funds were used to repair potholes in a specific ZIP code if there is no information on the percentage of potholes that were filled or the condition of roads in a given county? Time and analysis will help determine the extent to which the data should be rolled up to a higher level and analyzed to make it meaningful.

Data Integrity and Assurance Prior to any data being reported, many groups expressed concerns about integrity and consistency. Recovery Act data is generated from many sources and reported by different recipient groups. At a minimum, timing differences and control totals will need to be reconciled. Explainable differences will exist for many reasons, such as noncompliance or reporting errors on the part of recipients. Accumulating the volume of financial data for Recovery Act activity carries a significant risk of inaccurate, incomplete or inconsistent information. OMB has worked with the RATB to deploy a nationwide data collection system on FederalReporting.gov. More than 130,000 recipients filed information on the website for the first round of reporting, and they did so by October 10— just 10 days after the September 30 close of a quarter. Early reporting of Recovery Act spending was widely criticized when data was reported for congressional districts that did not exist. Members of Congress publicly questioned the validity of data indicating that $160 billion in spending had created or saved at least 640,000 jobs.2 Recently, the issue of data quality and integrity has received greater attention as the RATB and federal inspectors general have undertaken a coordinated review of the integrity and consistency of financial data being reported. In addition, OMB, in its Open Government Directive issued in December 2009, spoke directly to the issue of data quality and integrity. In early February 2010, OMB issued additional guidance defining a process, similar to the OMB Circular A-123 assessment process, for assessing internal controls over information on publicly reported websites. While dissatisfaction may exist with current financial reporting, audited financial statements have driven the establishment of basic disciplines and internal controls in federal financial management operations. These basic disciplines and internal controls are fundamental to the quality of any type or level of financial information. The annual financial audit process helps maintain these disciplines and fosters the need to follow them in connection with all financial management and information processes, not just GAAP-based financial statements. Further, in the past, attempts were made to combine and consolidate reporting requirements into one document, the annual Performance and Accountability Report (PAR). In trying to be everything to everybody, the Performance and Accountability Report’s audience is very broad and somewhat undefined. Efforts by OMB to split the report into a financial report and performance report have helped. However, credible and comprehensive assessment of users and users’ needs should be performed as a first step in evaluating the spectrum of financial reporting to demonstrate accountability for government spending. The public interest generated by Recovery.gov provides an opportunity to assess and improve federal financial reporting. What user groups are interested in this information, and are they representative of a broader public interest? A comprehensive study of users and their needs will add fur-

July 2010 11

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 12

REDEFINING ACCOUNTABILITY ther clarity to the relevance of financial information currently reported. Citizen-Centric Reporting One reporting option AGA has advocated is Citizen-Centric Report (CCR). This report can be focused on the government entity or on Recovery Act funds. Nevada’s Controller Kim Wallin issued a CCR on Recovery Act funds in January 2010. Wallin believes it serves as a key element in providing information to the public. Similarly, the Federal Aviation Administration (FAA) was one of the first federal agencies to issue a citizen-oriented Performance Highlights Report to enhance understanding and transparency over its programs. FAA has issued its Highlights Report since 2002. While Recovery.gov provides the public with unprecedented information about Recovery Act spending, the amount of data contained on the site is so vast that it can be difficult to get an overall picture of how stimulus funds actually benefitted a community, state or federal program. The Stimulus CCR can be prepared for the agency as a whole or just Recovery Act programs. The following are advantages to a two-page Stimulus CCR: • The report will be particularly useful for small, local governments, which generally don’t have the resources to develop and maintain elaborate websites. Governments can load their Recovery Act CCR on their website in a PDF file that can be downloaded by citizens. The report gives governments a simple format for getting out core information in a user-friendly, visually pleasing way. • Governments can be proactive in distributing their CCR by mailing it or making it available at popular locations, such as a driver’s license office. They don’t have to rely on citizens taking the initiative to access websites. • Many local governments do not have a good way of communicating financial information to their citizens. The report will allow local governments to be proactive in getting their message out. • The reports can help governments clarify discrepancies in some of the Recovery Act spending figures posted on various websites. For example, figures posted on Recovery.gov do not contain information about federal entitlement payments made directly to individuals. Because these payments may represent most of the money received by individual states in calendar year 2009, states tend to include information on these funds on their own websites, creating some confusion when citizens compare the data on Recovery.gov to state websites. In preparing its Stimulus CCR, Nevada was able to explain this discrepancy in information. The Stimulus CCR can help put information in perspective and clarify information that is known to be confusing.

12 AGA Corporate Partner Advisory Group Research

• Governments can use the CCR to communicate information that is not called for by Recovery.gov or that might get lost on a big, elaborate website. One option might be to describe what kind of money the government pursued but did not receive. It can help clarify the government’s thought process. Another example would be challenges the government may face in the future, such as the ability to maintain spending on education. • Small local governments can use the web links listed at the end of the report to direct citizens to key websites, not just to the more sophisticated state website and Recovery.gov. • Many local governments have not received funding from that many sources, but they still need to tell people what they are doing with their stimulus funds. Preparing the report will not be as difficult for them as it is for a state that has a much more complicated funding stream. Intergovernmental Cooperation The federal government took a bold step when it required 130,000 entities to build a nationwide database. Unfortunately, there were highly publicized problems when the initial data was released on October 30, 2009. Had there been an official forum for collaboration, some of the problems might have been avoided. For example, state and local governments would have had an official forum for explaining the perils associated with calculating and reporting the number of Recovery Act jobs created and retained. The Recovery Act presented a number of other intergovernmental implementation challenges. Many of these challenges revolved around implementation of recipient and sub-recipient reporting. While federal agencies expanded outreach on communication, the implementation experience provided an opportunity to look at the possibility of a more formal way to facilitate the dialogue between the federal government and state and local partners. One option that has been advocated by AGA is the establishment of an ongoing forum to obtain input on broad issues from its intergovernmental partners. In addition, to help renew public confidence and trust in government, the forum should be well publicized. The new forum could foster communication on topics that would improve the way joint programs are operated and overseen. The public should be made aware of any new intergovernmental partnerships. Publicizing the forum would help restore public confidence in government and help restore public trust by demonstrating that all levels of government are engaged and working together. A white paper issued by the International City/County Management Association in July 2009 concluded that there is “…a compelling need for a new kind of collaboration and enhanced bottom-up communication from the state and local level to the federal level. There also appears to be a lack of general awareness as to the magnitude and extent of the challenges faced by state and local governments under the status quo. Currently, there is no single body that is devoted to studying and suggesting remedies for strains within the intergovernmental system...” The white paper called for creation of a core council of 20 to 25 federal, state and local officials.

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 13

RECOVERY ACT PRACTICES AND OPPORTUNITIES The Open Government Directive issued on December 8, 2009 requires the deputy director for Management at OMB, the federal chief information officer and the federal chief technology officer establish a working group that focuses on federal transparency, accountability, participation and collaboration. Among other things, the work group will provide a forum to share best practices on innovative ideas to promote participation and collaboration, including how to experiment with new technologies, take advantage of the expertise and insight of people both inside and outside the federal government, and form high-impact collaborations with researchers, the private sector and civil society. While the working group is a positive step, it should include state and local members, and it should be constituted in a way that will enable it to transition between administrations. The working group called for by the directive does not appear to have the stature or composition needed to make lasting progress in intergovernmental relations, in part because it is questionable as to whether it will continue in future administrations. The opportunity for a more formal forum would include high-level federal, state and local government officials, as well as representatives from nonprofit organizations. The forum can be structured so that it has a direct line of communication to OMB, while providing a neutral setting in which all participants can provide candid input. The forum could address many issues, including: • How to leverage and avoid duplication in the implementation of various federal laws, including GPRA, GMRA, the Single Audit Act Amendments of 1996 and IPIA. • How to avoid gaps or duplication in government guidance, regardless of whether it is issued at the federal or the state level of government. • How to avoid information overload and provide for the meaningful analysis of data on joint programs, including the appropriate use of data visualization. • Whether the level of effort devoted to Recovery Act implementation and reporting is, or should be, sustainable. • How to adopt a “prudent person” approach to the oversight of programs, particularly for new programs. • Whether the government’s transparency goals can be met by data, information or a combination of both. • The costs and benefits of assurance at the different levels of reporting. • How, when and where raw data should be published. • How to develop and maintain reporting formats and technical requirements for nationwide databases, such as FederalReporting.gov, that are populated in part by nonfederal entities.

Conclusion Implementation of the Recovery Act ushered in a new era of transparency and accountability in the federal government and its state and local partners. Risk assessment and management have been aggressively implemented, independent oversight is being done sooner and with a focus on prevention and flagging risks before they become problems, the reporting of federal spending information is much more detailed and is in publicly accessible formats, and intergovernmental training and communication channels have expanded. Many of the practices can be traced back to lessons learned from earlier experiences, such as Hurricane Katrina, while others are rooted in statutes, such as the Transparency Act, as well as transparency initiatives undertaken by OMB. Regardless, the introduction and implementation of these practices results in opportunities to: • Better manage program and financial reporting risks through improved risk assessment. • Prevent fraud, waste and abuse through more proactive oversight. • Improve the quality and focus of federal financial reporting, including federal spending information, through a clearer understanding of users and their needs. • Strengthen intergovernmental communication and coordination through a more formalized structure. Now is the time to strategically assess each of these opportunities to improve elements of the federal financial management and accountability framework.

End Notes 1. “Hurricanes Katrina and Rita Disaster Relief: Prevention Is the Key to Minimizing Fraud, Waste, and Abuse in Recovery Efforts,” 110th Congress, 1st Session (January 29, 2007) Statement of Gregory Kutz, Managing Director Forensic Audits and Special Investigations, GAO, before the Committee on Homeland Security and Governmental Affairs, U.S. Senate, GAO-07-418T. 2. Government Executive, October 30, 2009, “States Reported Saving 640,000 Jobs through Recovery Act,” article by Robert Brodsky.

July 2010 13

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 14

NOTES

14 AGA Corporate Partner Advisory Group Research

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 15

NOTES

July 2010 15

394037_AGA:394034_AGA 6/25/10 4:15 AM Page 16

AGA CPAG Research Reports No. 1, March 2005:

Audit Federal Financial Controls: Sooner Rather than Later?

No. 2, July 2005:

Financial Management Shared Services: A Guide for Federal Users

No. 3, November 2005: Trends in Technology No. 4, April 2006:

The Federal Purchase Card: Use, Policy and Practice

No. 5, June 2006:

Challenges in Performance Auditing: How a State Auditor with Intriguing New Performance Authority is Meeting Them

No. 6, June 2006:

PAR—The Report We Hate to Love

No. 7, February 2007:

The State Purchase Card: Uses, Policies and Best Practices

No. 8, March 2007:

Federal Real Property Asset Management

No. 9, May 2007:

Should State and Local Governments Strengthen Financial Controls by Applying SOX-Like Requirements?

No. 10, April 2007:

Process-Based Financial Reporting

No. 11, May 2007:

The State Travel Card—Uses, Policies and Best Practices

No. 12, June 2007:

Trends in Technology—2007 Review

No. 13, June 2007:

The Federal Travel Card—Uses, Policies and Best Practices

No. 14, January 2008:

21st Century Financial Managers—A New Mix of Skills and Educational Levels?

No. 15, July 2008:

SAS 70 Reports: Are they Useful and Can They Be Improved?

No. 16, Sept. 2008:

XBRL and Public Sector Financial Reporting: Standardized Business Reporting: The Oregon CAFR Project

No. 17, Nov. 2008:

Characteristics of Effective Audit Committees in Federal, State and Local Governments

No. 18, Jan. 2009:

Grants Management: How XBRL Can Help

No. 19, Feb. 2009:

Procuring Audit Services in Government: A Practical Guide to Making the Right Decision

No. 20, March 2009:

Performance-Based Management

No. 21, June 2009:

Trends in Technology—2009 Review

No. 22, Sept. 2009:

Managerial Cost Accounting in the Federal Government: Providing Useful Information for Decision Making

No. 23, Nov. 2009: No. 24, June 2010:

State and Local Governments' Use of Performance Measures to Improve Service Delivery Creating an Interactive Single Audit Database

Advancing Government Accountability Association of Government Accountants 2208 Mount Vernon Avenue Alexandria, VA 22301 PH: 703.684.6931 TF: 800.AGA.7211 FX: 703.548.9367 www.agacgfm.org [email protected]