Financial Management Systems

This Circular prescribes policies and procedures to be followed by executive departments and agencies in develop-ing, operating, evaluating, and reporting on financial management systems.

The Budget and Accounting Procedures Act of 1950, the Federal Managers Financial Integrity Act, and related legislation (See Attachment) provide that:

	· Establishing and maintaining systems of accounting and reporting is the responsibility of the executive branch.
	· Agency systems shall provide for:
	· complete disclosure of the financial results of the activities of the agency,
	· adequate financial information for agency management and for formulation and execution of the budget,
	· effective control over revenue, expenditure, funds, property, and other assets. Full consideration shall be given to the needs and responsibilities of the Congress and the `executive branch in systems design and reporting.
	· In consultation with the Secretary of the Treasury and the Director of the OMB and considering the needs of other executive agencies, the Comptroller General shall prescribe accounting principles and standards.
	· Each agency head shall report to the President and Congress annually on whether the agency's accounting system complies with principles and standards developed by the Comptroller General and implemented through OMB guidelines.

This Circular provides guidance to agencies on meeting those requirements and on reviewing systems, correcting weaknesses, and reporting under Section 4 of the Federal Managers Financial Integrity Act.

Policy.

For the purposes of this Circular, the following definitions apply:

a.Agency-any department or independent establishment in the executive branch including Government corporations.

b.Financial management information-information on Federal spending, collections, assets, liabilities, equity, and related budgetary transactions and balances. This also includes data used to develop information for decisionmaking regarding unit costs, average pay rates, user charges, etc. c. Accounting system-the system for recording, classifying, and summarizing information on financial position and operations. d. Agency financial management system-the total of agency financial systems, both manual and automated, for planning, budget formulation and execution, program and administrative accounting, and audit; as well as all other systems for recording and classifying financial data and reporting financial management information, including purchasing, property, inventory, etc.

Responsibility.

The head of each agency is responsible for ensuring that the planning, development, operation, review and reporting on the agency's financial management system are in accordance with this Circular. The manager of each financial system has responsibilities for performance of necessary system reviews and for issuance of reports thereon. These responsibilities are described in Sections 5b and c. The Inspector General (SC), or equivalent in agencies without an IG, has limited responsibility in regard to financial systems, as explained in Section Sd. Top agency management, as well as program and functional managers, shall participate in systems planning and evaluation to ensure that their needs are met.

	a. Agency heads are responsible for establishing and properly maintaining the financial management system within their agencies. This includes ensuring that the system is operating as required by this Circular.
	b. A designated senior official shall be responsible for coordinating the overall agency-wide effort of reviewing, improving, and reporting on the financial systems in accordance with this Circular.
	c. A manager shall be named as the responsible individual for each system in the agency's inventory of financial systems. This responsibility includes ensuring that the system is established, maintained, reviewed, improved and reported upon in accordance with the requirements of this Circular.

d.The IG, or the senior audit official where there is no SC, should provide technical assistance and advice in the agency effort to review and improve the agency's financial management system. This would be in addition to the reviews of financial systems undertaken at the IG's initiative or at the request of the agency head, and the reports issued as a result of these reviews.

e.In addition, the IG should advise the agency head whether the agency's financial management system review has been conducted in accordance with the OMB guidelines. Per-forming the limited review required to include such advice should not be interpreted as precluding the IG from providing technical assistance in the agency effort to evaluate and improve the financial management system, or otherwise limit the authority of the IG. The extent of IG involvement should be coordinated among the agency head, the IG and the designated financial management system manager.

Financial Management System Objectives.

The following objectives shall be met by the agency financial management system in complying with applicable law and appropriate guidance of GAO, Treasury, and OMB. Additional details regarding these objectives are contained in an OMB document to be issued separately, "Financial Management and Accounting Objectives." Where objectives appear to conflict with other guidance, agencies shall communicate the particulars of the issue to OMB for resolution.

a. Systems operations-the agency financial management system shall use the best of acceptably priced, contemporary technology-including automated data entry and edit, data management, data base dictionaries, electronic communications between systems, flexible report formats, and controlled access to data bases by personal computers and other means-to achieve the following objectives.

	· Usefulness-financial management data shall be gathered and processed only where necessary to meet specific internal management needs or external requirements. Reports shall be tailored to specific user needs and if report usage does not justify cost, reports shall be terminated. Usefulness shall be determined in part through consultation with users as part of the reviews required by Section 7b of this Circular.
	· Timeliness-financial management data shall be recorded as soon as practicable after the occurrence of the event, and relevant preliminary data shall be made available to managers by the fifth working day following the end of the reporting period. Other standards of timeliness may be established where the agency has inventoried reports and set specific standards, with user participation. Final, corrected data shall be available in time to meet external reporting requirements.
	· Reliability and completeness-financial management information shall be reasonably complete and accurate, shall be verifiable and ordinarily be drawn from the official records and systems, and shall be no more detailed than necessary to meet the needs of management and external requirements.
	· Comparability and consistency-financial management data shall be recorded and reported in the same manner throughout the agency, using uniform definitions. Accounting shall be synchronized with budgeting. Consistency over time shall be maintained. New and revised systems shall adopt common, existing definitions and classifications.

· Efficiency and economy-the agency financial management system shall be designed and operated with reason-able total costs and transaction costs, in accordance with OMB guidelines. Financial systems which are excessively costly shall be identified and phased out. This shall be accomp-lished through installation of effective systems of planning and evaluation, sharing of data, elimination of overlap and duplication, and use of the best contemporary technology, including commercially available packages with proven success in other agencies or the private sector.

	b. Systems integrity-the agency financial management system shall feature reasonable controls designed, operated, and evaluated in accordance with OMB Circular A-I 23, "Internal Control Systems," and A-11, "Responsibilities for the Adminis-tration and Management of Automatic Data Processing Facilities."
	c. Support for budgets-financial management data shall be recorded, stored, and reported to facilitate budget prepa-ration, analysis, and execution. Data shall be classified uniformly and that classification, at a minimum, shall be at a level of detail that directly supports execution of enacted budgets and formulation of proposed budgets, without excessive aggregation or disaggregation.

presidential and Congressional decisions shall be recorded precisely and financial management data on results shall be classified to track such decisions. This includes detailed support for reports to OMB under Circular A- 34, "Budget Execution," as required by OMB, and for routine budget submission materials under Circular A-II, "Preparation and Submission of Budget Estimates." Data required for budget and management decisionmaking on unit costs and performance shall be included in the system.

d. Support for management-Data shall be recorded and reported in a manner to facilitate carrying out the responsi-bilities of both program and administrative managers. The agency financial management system shall provide for a coherent, timely, and accurate financial management data base. It should be supplemented as necessary to meet agency manage-ment and Executive Office requirements for administrative data, such as the Financial and Administrative Management Information System. Accrual accounting information shall be developed only as needed for pricing purposes, comparative cost analyses, and to meet the needs of management or the Congress.

e. Full financial disclosure-financial management data shall be recorded, and reported as specifically required by OMB or Treasury, to provide for full financial disclosure and accountability in accordance with appropriate budget and accounting principles and standards. Financial disclosure requirements are met through the Budget, the Treasury Combined Statement, and related documents. Agencies contribute to this disclosure through required reports to OMB, Treasury, and the Congress and through proper recording and classifying of financial data. Any other financial statements intended for use by the public shall be submitted to OMB for review and approval, and shall be evaluated on the basis of costs and benefits and for consistency with the Budget.

Required Actions

Each agency shall take the following actions:

	· Within 90 days of the publication of this Circular, each agency head shall issue a directive providing policy guidance and assigning responsibilities. The directive shall require establishment of a single integrated financial manage-ment system and include a list of existing and proposed finan-cial systems making up that system. A copy of the directive, annual updates to the systems listing, and revisions to the directive shall be sent to OMB.
	· The directive shall assign overall responsibility, as well as responsibility for each system making up the agency system, make specific assignments, specify actions to be taken, and provide for management follow-up to insure full implementation of the policies contained in this Circular.
	· The directive shall insure that managers using financial information for decisionmaking are involved in systems planning and evaluation, and that funds are not expended for financial systems, except as provided in the agency plan required under Section lc of this Circular. The directive will assure that all systems using financial management data shall acquire such data from financial systems contained in the inventory.

Annual review of agency financial systems.

· A review shall be conducted annually by system managers and users in accordance with an OMB review guide to be issued separately, "Guidelines for Evaluating, Improving, and Reporting upon Financial Management/Accounting systems." The review will build upon reviews required by OMB Circular A-I 23, "internal Control Systems, and result in a documented management assessment of how well the agency's financial management system and component systems conform to Section 6 objectives. More detailed evaluations of agency financial systems shall be conducted on a cyclical basis. · Review results shall be used as a basis for the financial management system plan required under action 7c of this Circular to ensure that all deficiencies are addressed. · As part of this review, failures to conform to objectives implementing appropriate accounting principles and standards shall be noted and included in reports on accounting systems under Section 8 of this Circular.

c. Developed and maintain an agency financial management system plan.

	· Develop a five-year plan for a single integrated, efficient agency financial management system. The plan shall be approved by the agency head and accompany each year's' budget and management submission to OMB, beginning with the FY 1987 budget. Materials submitted shall be adequate to support the development of an overall executive branch management report to Congress.
	· The plan shall feature specific milestones and obligation and outlay estimates for each financial system making up the agency's financial management system. It shall feature a review and change approval process and be coordinated with the information technology five-year plan.

Reporting.

As required by Section 4 of the Federal Managers Financial integrity Act, the head of each executive agency subject to the act shall report to the President and the Congress on whether the agency's accounting system conforms to appropriate accounting principles and standards. Systems that conform to the provisions of this Circular shall be considered as meeting the requirements of the Act. This report shall be made by December 31 of each year for the year ending September 30.

This report may be made part of the internal control reports required by Section 2 of the Act and OMB Circular A-123. It is to be based on the agency accounting system as defined in paragraph 4c. It should reflect the agency head's judgment of conformance, based on the review performed under Section 7b of this Circular.

	9. Effective Date. This Circular is effective on publication.
	10. Inquiries. All questions or inquiries should be addressed to the Financial Management Division, Office of Management and Budget, telephone number 202/395-3993.

II. Sunset Review Date. This Circular shall have an independent policy review to ascertain its effectiveness three years from the date of issuance.

David A. Stockman

Director

Attachment

(No. A-127)

SELECTED LEGAL REQUIREMENTS RELATED TO FINANCIAL MANAGEMENT SYSTEMS

© The head of an agency shall include with an appropriation request submitted to the President a report that the statement of obligations submitted with the request contains obligations consistent with section 1501 of this title. The head of the agency shall support the report with a certification of the consistency and shall support the certification with records showing that the amounts have been obligated. The head of the agency shall designate officials to make the certifications, and those officials may not delegate the duty to make the certifica- tions. The certifications and records shall be kept in the agency-

	(1) in a form that makes audits and reconciliations easy, and
	(2) for a period necessary to carry out audits and reconciliations.

31 U.S.C. 3511

prescribing accounting requirements and developing accounting systems

(a) The Comptroller General shall prescribe the accounting principles, standards, and requirements that the head of each executive agency shall observe. Before prescribing the principles, standards, and requirements, the Comptroller General shall consult with the Secretary of the Treasury and the President on their accounting, financial reporting, and budgetary needs, and shall consider the needs of the heads of the other executive agencies.

(9) Requirements prescribed under subsection (a) of this

section shall-

(1) provide for suitable integration between the accounting process of each executive agency and the accounting of the Department of the Treasury; (2)allow the head of each agency to carry out section 3512 of this title; and (3)provide a method of- (A) integrated accounting for the United States

Government;

	(B) complete disclosure of the results of the financial operations of each agency and the Government; and
	(C) financial information and control the President and

Congress require to carry out their responsibilities.

Consistent with subsections (a) and (b) of this section-

	(1) the authority of the Comptroller General continues under section 205(b) of the Federal Property and Administrative Services Act of 1949(40 U.S.C. 486(b)); and
	(2) the Comptroller General may prescribe the forms, systems, and procedures that the judicial branch of the Government (except the Supreme Court) shall observe.
	(d)The Comptroller General, the Secretary, and the President

(a) The head of each executive agency shall establish and maintain systems of accounting and internal controls that provide- (1) complete disclosure of the financial results of the activities of the agency; (2) adequate financial information the agency needs for management purposes; (3) effective control over, and accountability for, assets for which the agency is responsible, including internal audit (4) reliable accounting results that will be the basis for- (A) preparing and supporting the budget requests of the agency; (B) controlling the carrying' out of the agency budget; and (C) providing financial information the President requires under section 1104(e) of this title; and (5) suitable integration of the accounting of the agency with the central accounting and reporting responsibilities of the Secretary of the Treasury under section 3513 of this title.

3

	(A) obligations and costs comply with applicable law;
	(B) all assets are safeguarded against waste, loss, unauthorized use, and misappropriation; and (C) revenues and expenditures applicable to agency operations are recorded and accounted for properly so that accounts and reliable financial and statistical reports may be prepared and accountability of the assets may be maintained.

	(2) Standards the Comptroller General prescribes under this subsection shall include standards to ensure the prompt resolution of all audit findings.
	©(1) In consultation with the Comptroller General, the

Director of the office of Management and Budget-

	(A) shall establish by December 31, 1982, guidelines that the head of each executive agency shall follow in evaluating the internal accounting and administrative control systems of the agency to decide whether the systems comply with subsection (b) of this section; and
	(B) may change a guidelines when considered necessary.

(2) By December 31 of each year (beginning in 1983), the head of each executive agency, based on an evaluation conducted according to guidelines prescribed under paragraph (1) of this subsection, shall prepare a statement on whether systems of the agency comply with subsection (b) of this section, including- (A) If the head of an executive agency decides the systems do not comply with subsection (b) of this section, a report identifying any material weakness in the systems and describing the plans and schedule for correcting the weakness; and (B) a separate report on whether the accounting system of the agency conforms to the principles, standards, and requirements the Comptroller General prescribes under section 3511(a) of this title.

(3) The head of each executive agency shall sign the statement and reports required by this subsection and submit them to the President and Congress. The statement and reports are available to the public, except that information shall be deleted from a statement or report before it is made available if the information specifically is- (A) prohibited from disclosure by law; or (B) required by Executive order to be kept secret in the interest of national defense or the conduct of foreign affairs.

INTRODUCTION

Federal agencies are required to maintain an integrated financial system to meet certain objectives, including:

	· Support for the formulation and execution of the budget.
	· Support for management and control of programs, funds, and other resources.
	· Full disclosure of information necessary to enable executive branch officials, the Congress, and the public to evaluate the control of Government activities.

This document provides guidelines for the annual review of financial management systems required by Circular A-127, and for preparing the agency financial management improvement plan. It also provides guidance for preparing the annual report to the President and the Congress on accounting systems retired by Section 4 of the Federal Managers Financial Integrity Act, P.L. 97-255, (FMFIA).

These guidelines outline a process for agency management to use in evaluating their systems. Many of the features are the same as those in OMB's Guidelines for the Evaluation and Improvement of and Reporting on Internal Control Systems in the Federal Government and an earlier draft of this guideline which was used by a number of agencies for initial implementation of the Financial Integrity Act.

FINANCIAL SYSTEM OBJECTIVES

The financial system objectives set forth in Circular A-127 are summarized below. The detailed descriptions of these objectives, in Financial Management and Accounting Objectives, are to be used in making the required evaluations.

	· Systems operations
	· -the agency financial management system shall use the best of acceptably priced, contemporary technology-including automated data entry and edit, data management, data base dictionaries, electronic communications between systems, flexible reporting formats, controlled access to data bases by personal computers, and other means-to achieve the following objectives.
	· Usefulness
	· -financial management data shall be gathered and processed only there necessary to meet specific internal management needs or external requirements. Reports shall be tailored to specific internal management needs or external requirements. Reports shall be tailored to specific user needs and if report usage does not justify cost, reports shall be terminated.
	· Timeliness
	· -financial management data shall be recorded as soon as practicable after the occurrence of the event, and relevant preliminary data shall be made available to managers by the fifth working day following the end of the reporting period. Other standards of timeliness may be established where the agency has inventoried reports and set specific standards, with user participation. Final, corrected data shall be available in time to meet external reporting requirements.
	· Reliability and completeness
	· -financial management information shall be reasonably complete and accurate, shall be verifiable and ordinarily be drawn from the official records and systems, and shall be no more detailed than necessary to meet the needs of management and external requirements.
	· Comparability and consistency-financial management data shall be recorded and reported in the same manner throughout the agency, using uniform definitions. Accounting shall be synchronized with budgeting. Consistency over time shall be maintained New and revised systems shall adopt common, existing definitions and classifications.
	· Efficiency and economy-the agency financial management system shall be designed and operated with reasonable total costs and transaction costs. Financial systems which are excessively costly shall be identified and phased out. This shall be accomplished through installation of effective systems of planning and evaluation, sharing of data, elimination of overlap and duplication, and use of the best contemporary technology, including commercially available packages with proven success in other agencies or the private sector.
	· Systems integrity-the agency financial management system shall feature reasonable controls designed, operated, and evaluated in accordance with OMB Circulars A-123, "Internal Control systems, and A-71, "Responsibilities for the Administration and Management of Automatic Data Processing facilities.
	· Support for budgets
	· -financial management data shall be recorded, stored, and reported to facilitate budget preparation, analysis, and execution. Data shall be classified uniformly and that classification, at a minimum, shall be at a level of detail that directly supports execution of enacted budgets and formulation of proposed budgets, without excessive aggregation or disaggregation.

Presidential and Congressional decisions shall be recorded precisely and financial management data on results shall be classified to track such decisions. This includes detailed support for reports to OMB under Circular A-34, "Budget Execution," as required by OMB, and for routine budget submission materials under Circular A-II, "Preparation and Submission of Budget Estimates." Data required for budget and management decisionmaking on unit costs and performance shall be included in the system.

· Support for management

· -data shall be recorded and reported in a manner to facilitate carrying out the responsibilities of both program and administrative managers. The agency financial management system shall provide a coherent, timely, and accurate financial management data base. It should be supplemented as necessary to meet agency management and Executive Office requirements for administrative data, such as the Financial and Administrative Management Information System.

Accrual accounting information shall be developed only as

needed for pricing purposes, comparative cost analyses, and to meet the needs of management or the Congress.

· Full financial disclosure

· -financial management data shall be recorded, and reported as specifically required by OMB or Treasury, to provide for full financial disclosure and accountability in accordance with appropriate budget and accounting principles and standards. Financial disclosure requirements are met through the Budget, the Treasury Combined Statement, and related documents. Agencies contribute to this disclosure through required reports to OMB, Treasury, and the Congress and through proper recording and classifying of financial data. Any other financial statements intended for use by the public shall be submitted to OMB for review and approval, and shall be evaluated on the basis of costs and benefits and for consistency with the Budget.

BASIC APPROACH

A review of the financial management/accounting systems can be approached in a number of ways. In most instances, however, a structured approach consisting of a series of well-defined steps, should be used. The recommended approach is comprised of five phases:

	· Organizing the evaluation.
	· Establishing the inventory.
	· Understanding the system.
	· Evaluating the system.
	· Using the evaluation results.

Each phase is summarized below and discussed in greater detail in separate chapters of these guidelines.

	· Organizing the evaluation. This includes determining the manner in which the evaluation will be made; assigning responsibilities to appropriate officials; providing proper training and supervision; documenting system operations and reviews; scheduling and tracking the reviews and the status of Improvement actions; and monitoring the overall process. (see Chapter II.)
	· Establishing the inventory. Agencies are expected to establish and maintain a single, integrated financial management system. These may be made of various components and sub-systems. Each of these system elements must be identified so that it can be evaluated. The inventory should include each existing and proposed financial system, component, and sub-system (both automated and manual) included in the overall financial management system. The inventory listing, and the name and title of the manager for each system, should be maintained on a current basis. A copy of the updated inventory listing of financial systems, together with any revisions to the agency's directive are to be sent to OMB annually. (See Chapter III.)
	· Understanding the system. This phase is to obtain a general understanding of how an agency's overall financial management system operates. It includes the development of information concerning the purpose and use of the various component systems and sub-systems making up the overall system, their relationship to each other, and how they function.

If not already available, this information should be developed based on interviews with knowledgeable officials, examination of system documentation, and observation of operating activities. It provides useful details of system operation and helps managers understand the overall system and evaluate its elements. (See Chapter IV.)

· Evaluating the system. Two types of evaluation must be made.

The first is an assessment of the agency's overall financial management system to determine whether the policies and objectives set forth in Circular A-127 are being met. This type of evaluation is required annually. The other type is a detailed evaluation of individual system components and sub-systems that includes testing of the requirements applicable to each objective. This may be made on a cyclical basis, but not less frequently than once every three years.

The annual assessment is management's self-evaluation of its financial system. As such, it is to be based on all available knowledge of the system-the strengths as well as weaknesses -- plus the results of prior evaluations, and recent reports of Inspectors Genera I, the General Accounting Office, and others.

The aim of this assessment is to determine whether there is reasonable, not absolute, assurance that the financial systems conform with the policies and objectives of Circular A-127.

Results are to be summarized in an overall system review report, with recommendations for necessary corrective action and priorities for taking the action. The report is to be used in preparing the required management system plan. It should be updated as necessary to consider the results of subsequent detailed evaluations of components and sub-systems.

Significant results of the evaluations also are to be included in the year-end accounting system report required by Section 4 of the Financial Integrity Act. (See Chapter V.)

· Using the evaluation results. Evaluations that disclose instances of nonconformance should result in plans for corrective action. These plans should be considered in preparing the financial systems plan to be included with the agency's budget and management submission. (See Appendix F.) Evaluations indicating that accounting systems do not conform to appropriate principles and standards are to be included in the year-end report to the President and the Congress. (See Chapter VI.)

This recommended approach is depicted in the following flowchart (Exhibit 1) and explained in detail in Chapters II through VI.

EXHIBIT 1

Several key matters need to be considered, including:

	· Assignment of responsibilities.
	· Selection and supervision of personnel.
	· Documentation.
	· Monitoring the process.
	· Scheduling evaluations.

ASSIGNMENT OF RESPONSIBILITIES

The head of each agency has overall responsibility for ensuring that the financial systems conform to the policies and objectives of Circular A-127. All levels of agency management should participate in systems planning and evaluation to ensure that their needs are met. Responsibilities must be delegated carefully to senior officials to ensure that the system evaluation, improvement, and reporting requirements are carried out effectively. These officials should provide the agency head with assurances that their responsibilities are being carried out. Three levels of management have responsibility for evaluating and improving agency financial management systems. The responsibilities of each, and of the Inspector General (IG) are described below.

	· The agency head has overall responsibility for establishing and maintaining the financial management system. This includes ensuring that the system is operating, reviews are conducted, plans developed, and reports issued as required by Circular A-127.
	· A senior official shall be designated for coordinating the agency-wide effort of reviewing, improving, and reporting on the financial systems. This official should provide assurance that the processes for evaluation of accounting systems have been carried out in accordance with these guidelines. (See Appendix C.)
	· A system manager shall be named for each system component or sub-system in the agency's inventory of financial systems. This responsibility includes ensuring that the system is in accordance with the requirements of Circular A-127 and these guidelines. The manager of each system should provide assurance that the system has been evaluated in accordance with these guidelines; and that the reports of the evaluation fairly portray the system. (See Appendix D. )

· The IG (or equivalent) should provide technical assistance and advice on the agency program to review and improve its financial management systems. This should be in addition to the reviews of financial systems undertaken by IGs.

· In addition, the IG should advise the agency head whether the accounting system review has been carried out in accordance with these guidelines (See Appendix E). Making the limited review required to provide such advice should not preclude the IG from providing technical assistance in the agency effort to evaluate and improve the financial management system, or otherwise affect the work of the IG. The extent of IG involvement should be coordinated among the agency head, the IG, and the designated senior financial management official.

SELECTION AND SUPERVISION OF PERSONNEL

Specific measures that should be taken to assure staff have an adequate understanding of requirements include:

· Orientation and Training-Orientation and training programs should be provided to these individuals early in the review cycle, in order to advise them what needs to be done and to ensure that the reviews begin with proper direction and emphasis. The personnel assigned should be provided with a copy of Circular A-127, the Financial Management and Accounting Objectives, these evaluation guidelines, central management directives such as OMB Circulars, Treasury Fiscal Regulations, etc., agency implementing directives, and any other technical publications that would be useful for making the reviews.

· Assignment of Personnel-Consideration should be given to using the "team approach" in which small groups of individuals conduct the evaluations jointly. This is particularly important where one review of a system is made to meet these requirements and those in Circulars A-71, "Responsibilities for the Administration and Management of Automatic Data Processing Activities," and A-123 "Internal Control Systems." This provides some assurance that the limitations of one reviewer can be offset by the strengths of another, thus increasing the quality of the evaluations. It also stimulates individual evaluator's thinking, and lessens the potential for biased conclusions. Under a "team approach", individuals with specialized expertise can be detailed from different organizations within an agency. The knowledge that each acquires from such an assignment can be used to improve the system in the team member's own organization.

	· Supervision-personnel assigned should be supervised adequately to assure that the reviews are thorough, conclusive, and carried out as planned. Regardless of the approach chosen for evaluation, the responsibility for ensuring that an appropriate review is made, the results of the review evaluated, and the necessary improvements implemented rests with the manager responsible for the system.
	· Technical Assistance-Technical assistance should be provided to employees assigned to the process. Uniform agency procedures to guide the annual review are encouraged, including the use of standard forms. Agency "experts" who can answer questions and provide other assistance should be designated and their names provided to the reviewers. periodic circulation of informal guidance and meetings of key personnel involved in the process are other means of exchanging information.
	· Quality Assurance-A quality assurance program should be established to ensure that the systems reviews are made in accordance with these guidelines in a thorough and conscientious manner, that they adhere to the agency's implementing instructions, and that they produce reliable results.

DOCUMENTATION

Documentation is important to the evaluation and improvement of financial management systems from two perspectives:

· System Documentation-Adequate written documentation should be developed and maintained. The financial management systems, transactions, and other significant events should be documented. The documentation should be kept up-to-date and be available for examination. System documentation should be in enough detail to permit a person knowledgeable of the agency's programs, and of systems generally, to review and obtain a comprehensive understanding of the operation of the system, component, and sub-system. Chapter IV discusses the documentation that should be developed and maintained to obtain an understanding of the agency's overall financial management system and its component parts.

· Documentation of the Evaluation-Documentation should identify the personnel involved and their roles, the review methods used, and the conclusions reached in the evaluation. This information will facilitate the development of plans for improving systems. It also will be useful for reviewing the validity of conclusions reached, assessing the performance of individuals involved in the evaluations, and making subsequent reviews.

MONITORING THE PROCESS

More specifically, the monitoring system should be used toe.

	· Schedule and track the progress of reviews to ensure that they are complete and timely.
	· Accumulate information regarding departures from policies and objectives detailed in Financial Management and Accounting Objectives.
	· Accumulate information on material instances of nonconformance with the appropriate budget and accounting principles and standards that should be considered in the five-year system improvement plan and/or the year-end report required by Section 4 of the Financial Integrity Act.

A procedure should be established to track the planned improvements in the financial management systems and to report on the implementation in subsequent updates of the plan.

SCHEDULING EVALUATIONS

Two separate but related products are to be developed annually as a result of systems evaluations:

	· An agency financial management systems plan, and
	· A report on the status of agency accounting systems required by Section 4 of the Financial Integrity Act.

The financial management system plan is to be included with the agency's budget and management submission, whereas the accounting system report is required by December 31 of each year. Sufficient evaluation work must be done each year to provide a basis for the plan and report.

A cycle of detailed evaluations should be planned so that each system component and sub-system is examined at least once every three years. Limited reviews are to be made for the remaining system components annually. Component systems and sub-systems scheduled to be discontinued or combined into other systems within the next two fiscal years need not be reviewed. A plan and schedule for making the necessary system reviews should be developed early in each fiscal year to help ensure that the reviews are completed by the time the review results are needed.

Scheduling of component system evaluations should be based on priorities considering known deficiencies and other factors. Priority considerations may include the size of the system in dollar activity and the full-time equivalent personnel involved in its operation; the newness of the system or the recency of major changes; the susceptibility of the system to loss or improper operation; the extent of prior difficulties with the system; and other problems as revealed by reports from the IG, GAO, and others.

In scheduling detailed system review work, consideration should be given to evaluations required by Circulars A-71, "Responsibility for the Administration and Management of Automatic Data Processing Activities," and Circular A-123, "Internal Control Systems." In achieving the objective of "System Integrity", it is intended that the evaluation work needed to satisfy the requirements of the three circulars be consolidated or coordinated to increase the efficiency and effectiveness of the effort.

CHAPTER III

	· Accounting system-the system for recording, classifying, and summarizing information on financial position and operations.
	· Agency financial management system-the total of agency financial systems, both manual and automated, for planning, budget formulation and execution, program and administrative accounting, and audit; as well as all other systems for recording and classifying financial data and reporting financial management information, including purchasing, property, inventory, etc.
	· Component and sub-system-components are major elements of an overall agency financial system. They may stand alone or be linked through electronic means. A sub-system is a feeder system that furnishes essential administrative or financial data to another component of the financial system.

An inventory record should be established for each identified system in operation and planned (which should be clearly identified as separate from systems in operation) containing at least the following data:

	· Title of the system.
	· Name of the organizational unit operating the system.
	· Type of system. e.g. general ledger, payroll, credit review, working capital.
	· Purpose of the system.
	· General system products (outputs).
	· General source data (inputs).
	· Year implemented and Year of last major revision.
	· System manager, i.e., name, title, address, and phone number of individual with direct control over design and/or operation of the system.
	· General descriptions as to type of transactions, with the approximate number processed annually by major type.
	· Interfaces with other systems. i.e. , sub-systems. supporting systems, etc.
	· Operating locations.
	· Major ADP characteristics. i.e., on-line, batch input. terminal input, etc.
	· Types of equipment. i.e., type of computer. types of terminals, computer center used, etc.
	· System improvements in existence or planned with (major enhancements or modificatiOns, new modules) commencement and estimated completion dates.

The inventory record should be used as a control device for scheduling and monitoring the evaluations, recording the instances of nonconformance, and scheduling and monitoring approved corrective or upgrade actions.

CHAPTER IV

The purpose of obtaining a more detailed understanding is to identify the sources of data and the information or other products produced, the supporting components and feeder elements, the organizations involved in the process, data flow and procedures used, the use made of the information or products produced, etc. This should assist in determining whether the system conforms with the policies and objectives set forth in Circular A-127 and other OMB guidance. A recommended approach to obtain a detailed understanding is to review system design and operating procedures manuals, or to take each system component included in the overview flowchart, identify its parts and functions, and describe them in 3 separate flowchart showing the operating activities or functions, and the data flows making up that element of the system. This second level flowchart should be followed by a brief narrative summary describing the key components, activities, responsibilities, data flows, and the nature of data processed and produced. The greater the detail in the flowchart, the less is required in the narrative. The following guidance should be useful for obtaining the detailed understanding of specific system components and sub-systems.

	1. Obtain the information necessary to prepare each flowchart by reviewing existing systems documentation and reports, interviewing appropriate personnel operating and using the system, reviewing forms generated or processed by the system, observing the operating activities, etc.
	2. Keep he flowchart simple. Avoid excessive detail that could make the flowchart confusing. Concentrate on the data flows, description of the data, and functions. Include sufficient detail to permit identification of the various parts of the system subject to examination.
	3. Flowchart the procedures, show the flow of data and events, to whom reports are sent, and present the narrative following the sequence of the chart. Ensure that the chart follows a logical sequence.
	4. Identify the points at which data enter and leave the system and the disposition of documents, data, or other products generated by the system.

A sample second level flowchart for a component of the financial management system with its summary narrative is presented in Appendix B.

CHAPTER V

The review should consist of a combination of three elements: (1) the application of existing knowledge of the overall system and its component parts, (2) a limited review of the system components and sub-systems, and (3) a detailed evaluation of individual systems and their component parts.

	· Application of General Knowledge. The application of existing knowledge of system characteristics and procedures by the system managers and users can be both time saving and productive. This knowledge may have been obtained through working experience with the systems, or by reviewing the results of previous evaluations, or recent IG, GAO, and other reports.
	· Limited Reviews. A simple, but structured procedure-that may take the form of a desk review-should also be used for the annual review of those system components not subject to detailed evaluation in the current year. The limited system review should be made by the system manager in consultation with the operators and users through the use of a questionnaire, checklist, or similar methodology. This review should be based on the characteristics presented in Financial Management and Accounting objectives. The review methodology should be tailored by each agency and its system managers to fit their particular circumstances and systems. The key factors that indicate conformance with Circular A-127 should also be incorporated into the review guide. Limited reviews should be made annually for each financial system component and sub-system not subject to detailed evaluation. Completion of the limited reviews provides a basis for preparation of the required plans and reports as well as for planning and making the subsequent detailed evaluations.
	· Detailed Evaluation. A detailed examination that includes transaction testing, should be made on a cyclical basis for each system component and sub-system. Each system should be examined and evaluated in detail at least once every three years. The purpose of the detailed evaluation is to identify practices and procedures that fail to conform to established criteria and provide a basis for improvement plans. An evaluation program, developed by the agency to meet its particular circumstances, is to be used as the basis for making the detailed evaluations. The program should provide appropriate criteria for testing and measurement, based upon the Financial Management and Accounting Objectives and the applicable requirements of law, regulation, or other authoritative sources. The detailed evaluations should include tests of a variety of transactions, selected on a valid sampling basis. Transactions should be traced through the system to determine how the system reacts and whether the reactions are in accordance with the criteria presented in the evaluation program. See Appendix H for additional guidance on testing systems.

Systems that are to be replaced or combined with others within the next two fiscal years need not be subjected to a detailed evaluation. Also, to the extent possible, the reviews required by Circulars A-71, A-123, and A-127 should be coordinated or consolidated to avoid duplication, overlap, or omissions, and to enhance the efficiency and quality of the overall review effort.

The results of the detailed evaluations should be used in the preparation of the financial management system plan and the Section 4, financial Integrity Act report. Some of the detailed evaluations may be completed after preparation of its financial management system plan and before the Section 4 report is submitted. Significant results from such evaluations must be reflected in subsequent revisions to the plan and the Section 4 report.

During the initial review of its financial management system, the agency should apply existing knowledge and make a limited revision of each system component add sub-system that is expected to continue in operation for more than two years.

Documentation and Responsibilities

Upon completion of each limited review or detailed evaluation, a report summarizing the results shall be prepared by the system manager. The report should summarize the nature, extent, and results of the review, and be submitted to the senior financial management official. A sample report that may be used to summarize the results of the review and satisfy the system manager's responsibility for providing a statement of assurance is presented in Appendix D.